jl616 Privacy Policy

1. About This Privacy Policy

This Privacy Policy is published by jl616 (hereinafter "jl616", "we", "us", or "our") and applies to all personal data collected from individuals who visit, register with, or use the jl616 online gaming platform accessible at jl616.club (the "Platform").

This Privacy Policy forms part of, and should be read together with, the jl616 Terms and Conditions. By creating a jl616 account or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

If you have questions about how jl616 processes your personal data or wish to exercise any of your rights under applicable law, contact details are provided in Section 14 of this Policy.

2. Data Controller Identity

For the purposes of the Philippine Data Privacy Act of 2012, jl616 operates as the Personal Information Controller (PIC) with respect to the personal data of its members and platform visitors. As the PIC, jl616 determines the purposes and means of processing personal data collected through the Platform.

Third-party service providers engaged by jl616 — including payment processors, identity verification providers, and game content studios — act as Personal Information Processors (PIP) where they process personal data on behalf of and under instruction from jl616.

3. Personal Data We Collect

jl616 collects the following categories of personal data. The specific data collected may vary depending on the services you use and the verification tier applicable to your account.

jl616 does not intentionally collect sensitive personal information such as racial or ethnic origin, religious beliefs, political opinions, or health data. If you choose to share such information voluntarily in support communications, it will be handled with additional care and used only for the purpose for which it was shared.

4. How We Collect Your Data

jl616 collects personal data through the following means:

• Direct submission: Information you actively provide during account registration, KYC verification, support interactions, and when completing forms on the Platform.
• Automated collection: Technical data collected automatically as you interact with the Platform, including IP addresses, device identifiers, session data, and gameplay logs generated by our gaming systems.
• Payment processors: Transaction reference data received from GCash, PayMaya, and Philippine banking partners when you complete deposits or withdrawals. jl616 does not store full payment credentials — only the references and identifiers necessary to process and record transactions.
• Identity verification providers: Confirmation data returned by KYC verification services when document verification is performed. Raw document images are processed by the verification provider and returned to jl616 only as a confirmed pass or fail result where technically possible.
• Cookies and similar technologies: As described in Section 9 of this Policy.

5. Purpose and Legal Basis for Processing

jl616 processes personal data only where a lawful basis for doing so exists under the Philippine Data Privacy Act. The following table summarizes our primary processing activities and their corresponding legal bases:

6. Sharing and Disclosure of Your Data

jl616 does not sell personal data to third parties. Your personal data may be shared with third parties only in the following circumstances and only to the extent strictly necessary:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank receive the transaction data necessary to process your deposits and withdrawals.
• Identity verification services: KYC and age verification providers receive copies of identity documents and selfie images as necessary to complete verification. These providers are contractually bound by data processing agreements consistent with Philippine data protection law.
• Game content studios: Your gaming activity data is transmitted to game providers (such as JILI Gaming) in a session-level format necessary to operate the games. These providers are contractually prohibited from using this data for purposes other than game delivery.
• Regulatory and law enforcement authorities: jl616 may be required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other Philippine government bodies where required by law or a valid legal order.
• Professional advisers: Legal, accounting, or other professional advisers engaged by jl616 may access personal data on a need-to-know basis and are bound by professional confidentiality obligations.

Where a transfer of personal data outside the Philippines occurs — for example, to a game studio or technology provider based abroad — jl616 ensures that appropriate safeguards are in place, including contractual protections consistent with the requirements of the Philippine Data Privacy Act and NPC regulations.

7. Data Retention Periods

jl616 retains personal data only for as long as it is necessary for the purposes for which it was collected, including the satisfaction of legal, regulatory, and accounting obligations.

• Active account data: Retained throughout the period your account is active plus a minimum post-closure retention period of five (5) years for compliance with Philippine AML and gaming regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the relevant transaction, as required by Philippine anti-money laundering legislation.
• Identity verification documents: Retained for the life of the account plus a minimum of five (5) years post-closure, or longer if required by regulatory authority instruction.
• Support communications: Retained for a minimum of two (2) years from the date of the final communication in each support case.
• Technical and analytics data: Aggregated or anonymized analytics data may be retained indefinitely as it no longer constitutes personal data. Raw technical logs are purged on a rolling 12-month cycle unless required for an active security investigation.

When personal data is no longer required and no legal or regulatory obligation requires its retention, jl616 will securely delete or anonymize the data using industry-standard methods that render it irrecoverable.

8. Security Measures

jl616 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and jl616's servers is encrypted using 256-bit TLS encryption — equivalent to the standard applied by major Philippine banks.
• Password hashing: Your account password is never stored in plain text. jl616 uses a strong cryptographic hashing algorithm with individual salting to ensure passwords cannot be recovered even in the event of a data breach.
• Access controls: Personal data is accessible internally only to jl616 staff who require access to perform their job functions. Access is governed by role-based permissions and all access events are logged.
• Two-factor authentication: jl616 offers SMS-based 2FA for all member accounts and applies 2FA internally for staff access to systems that process personal data.
• Intrusion detection: jl616 operates 24/7 security monitoring systems to detect and respond to unauthorized access attempts, unusual account activity, and potential security incidents.
• Regular security assessments: jl616's security posture is reviewed on a periodic basis, including vulnerability assessments of the Platform's technical infrastructure.

9. Cookies and Similar Technologies

jl616 uses cookies and similar browser-based technologies on the Platform for the following purposes:

• Essential cookies: Strictly necessary for the Platform to function, including session management, login state, and security tokens. These cannot be disabled without significantly impairing Platform functionality.
• Functional cookies: Used to remember your preferences and settings, such as language preferences and display options, across sessions.
• Analytics cookies: Used to collect anonymized or aggregated information about how the Platform is used, which pages are most visited, and where technical errors occur. This data is used to improve Platform performance and user experience.
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

You may control cookie settings through your browser's privacy settings. Blocking all cookies may prevent certain features of the jl616 Platform from functioning correctly. jl616 does not use third-party advertising or behavioral tracking cookies.

10. Children's Privacy

The jl616 Platform is strictly intended for individuals aged 21 years and above. jl616 does not knowingly collect, process, or store personal data belonging to minors. Age verification is applied at the point of registration and at subsequent verification stages.

If jl616 discovers that personal data has been collected from an individual under 21 years of age, the relevant account will be immediately suspended, the personal data will be deleted as soon as practicable, and — where appropriate — the matter may be reported to the relevant authorities.

11. Exercising Your Data Subject Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the rights summarized above and described in full detail below. To exercise any of these rights, contact jl616 via the details in Section 14 and provide sufficient information to identify your account.

• Right to be Informed: You have the right to be informed of the personal data jl616 processes about you, the purposes of processing, the recipients of your data, and your rights under applicable law. This Privacy Policy constitutes jl616's fulfilment of this obligation.
• Right to Access: You may request a copy of the personal data jl616 holds about you. jl616 will respond to access requests within thirty (30) calendar days of receiving a valid, verified request.
• Right to Correction: You may request correction of inaccurate, incomplete, or outdated personal data. Certain data — such as your registered mobile number — can be updated directly in your account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (where consent is the legal basis), or where processing is unlawful. Note that data retained pursuant to a legal obligation (such as AML retention requirements) cannot be erased until the mandatory retention period expires.
• Right to Object: You may object to the processing of your personal data on the basis of legitimate interests where you have grounds relating to your particular situation. You may also object at any time to processing for direct marketing purposes.
• Right to Data Portability: Where processing is based on your consent or on a contract, and processing is carried out by automated means, you may request a copy of your personal data in a structured, machine-readable format.
• Right to Lodge a Complaint: If you believe jl616 has processed your personal data in violation of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

jl616 will not discriminate against you for exercising your data subject rights. Exercising your rights will not affect the services available to your account, except where the exercise of a right necessarily requires restricting a service — for example, requesting erasure of an active account's data.

12. Data Breach Response

jl616 maintains a documented Data Breach Response Plan consistent with the requirements of the Philippine Data Privacy Act and NPC Circular No. 16-03. In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected data subjects, jl616 will:

• Notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, where feasible.
• Notify affected data subjects without undue delay where the breach is likely to result in a high risk to their rights — including risks to identity, financial harm, or unauthorized account access.
• Provide details in notifications of the nature of the breach, the data categories affected, the likely consequences, and the measures jl616 has taken or proposes to take to address the breach and mitigate its effects.

jl616 will document all personal data breaches regardless of severity, in accordance with the NPC's accountability requirements.

13. Changes to This Privacy Policy

jl616 reserves the right to amend this Privacy Policy at any time to reflect changes in data processing practices, legal or regulatory requirements, or Platform features. Material changes to this Privacy Policy will be communicated to registered members via the mobile number or contact details associated with their jl616 account, or via a prominent notice on the Platform, at least fourteen (14) days before the changes take effect.

Your continued use of the jl616 Platform following notification of material changes constitutes acceptance of the revised Privacy Policy. If you do not accept the revised Privacy Policy, you should cease using the Platform and contact jl616 to close your account.

The date of the most recent revision is displayed at the top of this page. You are encouraged to review this Privacy Policy periodically.

14. Contact Details and Data Privacy Officer

For all privacy-related inquiries — including requests to exercise your data subject rights, questions about this Privacy Policy, or to report a suspected data breach — please contact jl616 via the following:

• Data Privacy Officer Email: [email protected] — Subject line: "Data Privacy Request"
• Live Chat: Available daily 8:00 AM – 2:00 AM Manila time (UTC+8) via the jl616 Platform
• Platform Address: jl616.club

jl616 will acknowledge data subject requests within five (5) business days of receipt and will respond substantively within thirty (30) calendar days. Where a request is complex or involves a large volume of data, jl616 may extend this period by a further thirty (30) days and will notify you of the extension.

If you are not satisfied with jl616's response to a privacy complaint or data subject request, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.

This Privacy Policy was last reviewed and updated on January 1, 2026. jl616 reserves all rights not expressly granted herein.