855jl Privacy Policy

1.1 855jl is an online gaming platform operated for players in the Philippines. We are committed to protecting the privacy and personal data of every player who registers and plays on our platform. This Privacy Policy sets out in clear terms how we handle your personal information from the moment you visit our site to the time you close your account.

1.2 This policy applies to all personal data collected through the 855jl website, mobile browser interface, and any related communications channels including customer support, email, and live chat. It applies to all registered players, prospective players, and visitors to the 855jl platform.

1.3 By accessing or using 855jl, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this policy, you should discontinue use of the platform.

1.4 This Privacy Policy should be read together with our Terms & Conditions and our Responsible Gaming policy, both of which are incorporated by reference.

2.1 855jl collects the following categories of personal data from players:

2.2 We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data unless specifically required for responsible gaming purposes (e.g., self-exclusion requests) and only with your explicit consent.

3.1 Directly from you. The majority of personal data we hold is provided directly by you when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions.

3.2 Automatically. When you access the 855jl platform, we automatically collect certain technical and usage data through cookies, web beacons, log files, and similar tracking technologies. This includes your IP address, device identifiers, browser type, and browsing behaviour on our platform.

3.3 From third parties. We may receive personal data about you from third-party sources in the following circumstances:

• Payment processors (e.g., GCash, PayMaya, BPI, BDO, Metrobank) who confirm transaction details;
• Identity verification service providers who assist with KYC compliance;
• Fraud prevention and anti-money laundering screening services;
• Regulatory authorities such as PAGCOR, where required by law.

3.4 From publicly available sources. In limited circumstances, we may collect information from publicly available sources to verify the accuracy of information you have provided or to fulfil our legal obligations.

4.1 855jl uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 855jl player account, including processing your registration and verifying your identity;
• Service Delivery: To provide you with access to our games, process your deposits and withdrawals, and deliver the core gaming experience;
• KYC & Age Verification: To verify that you meet the minimum age requirement of 21 years as required under Philippine gaming regulations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, money laundering, and other illegal activities on the platform;
• Regulatory Compliance: To comply with our obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Responsible Gaming: To monitor gaming behaviour and implement responsible gaming tools such as deposit limits, session limits, and self-exclusion where requested or required;
• Marketing & Promotions: To send you information about 855jl promotions, bonuses, and new games — but only where you have given your consent to receive such communications;
• Platform Improvement: To analyse usage patterns and improve the functionality, performance, and user experience of the 855jl platform.

4.2 855jl will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by applicable law.

5.1 Under the Philippine Data Privacy Act of 2012, 855jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your player account, process transactions, and deliver gaming services;
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AMLA obligations, and NPC directives;
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and freedoms;
• Consent: For certain processing activities — such as sending marketing communications or processing sensitive personal information — we rely on your explicit consent, which you may withdraw at any time.

5.2 Where we rely on consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out prior to the withdrawal.

6.1 855jl does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following limited circumstances:

• Service Providers: We share data with trusted third-party service providers who assist us in operating the platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, IT infrastructure providers, and customer support platforms. These providers are contractually bound to process your data only on our instructions and to maintain appropriate security measures;
• Game Providers: Certain technical data (such as session identifiers) may be shared with our licensed game providers to facilitate gameplay. Game providers do not receive your full personal profile;
• Regulatory Authorities: We are required by law to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other relevant Philippine government authorities upon lawful request;
• Law Enforcement: We may disclose personal data to law enforcement agencies where required by a valid court order, subpoena, or other legal process under Philippine law;
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of 855jl's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

6.2 Any third party with whom we share your personal data is required to handle it in accordance with applicable data protection laws and our data processing agreements. We do not permit our service providers to use your data for their own purposes.

7.1 855jl uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and gather analytics data. A cookie is a small text file placed on your device when you visit our website.

7.2 We use the following types of cookies:

• Strictly Necessary Cookies: These are essential for the platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled;
• Performance & Analytics Cookies: These cookies collect anonymised information about how visitors use the 855jl platform, such as which pages are visited most frequently. This data helps us improve the platform's performance and user experience;
• Functional Cookies: These cookies remember your preferences (such as language settings and display options) to provide a more personalised experience;
• Targeting & Marketing Cookies: These cookies may be used to deliver relevant promotional content based on your interests and browsing behaviour on the 855jl platform. They are only set with your consent.

7.3 You can 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 855jl platform. For instructions on managing cookies in your specific browser, refer to your browser's help documentation.

8.1 855jl implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Strict access controls ensuring that only authorised personnel can access personal data, on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing of our platform infrastructure;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Employee training on data protection obligations and security best practices.

8.2 While 855jl takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we are committed to promptly addressing any security incidents that may occur.

8.3 Data Breach Notification. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 855jl will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, as required by the Data Privacy Act of 2012. Affected players will be notified without undue delay where the breach is likely to result in a high risk to their rights.

9.1 855jl retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements.

9.2 The following general retention periods apply:

• Account Data: Retained for the duration of your active account and for a period of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and AMLA obligations;
• Transaction Data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act;
• KYC Documents: Retained for five (5) years following account closure or the completion of the relevant transaction, whichever is later;
• Customer Support Records: Retained for three (3) years from the date of the last interaction;
• Marketing Consent Records: Retained for as long as you remain opted in, plus three (3) years following opt-out to demonstrate compliance.

9.3 When personal data is no longer required, 855jl will securely delete or anonymise it in a manner that prevents reconstruction or identification of the individual concerned.

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 855jl:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy;
• Right of Access: You have the right to request a copy of the personal data that 855jl holds about you, along with information about how it is being processed;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update certain information directly through your account settings;
• Right to Erasure: You have 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 our legal retention obligations;
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests;
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible;
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that your data protection rights have been violated.

10.2 To exercise any of the above rights, please contact our Data Protection Officer using the contact details provided in Section 14 of this policy. We will respond to all valid requests within thirty (30) days, as required by the Data Privacy Act of 2012.

11.1 855jl is strictly an adult gaming platform. Access to real-money gaming on 855jl is limited to persons who are at least twenty-one (21) years of age, as required by Philippine gaming regulations administered by PAGCOR.

11.2 855jl 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 close the associated account, return any deposited funds to the originating payment method, and delete all personal data associated with that account.

11.3 If you believe that a minor has registered an account on 855jl, please contact our support team immediately so that we can take appropriate action.

12.1 The 855jl platform may contain links to third-party websites or services, including payment provider portals. This Privacy Policy applies only to the 855jl platform and does not cover the privacy practices of any third-party websites or services.

12.2 855jl 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 services you access through or in connection with the 855jl platform.

13.1 855jl reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision will always be displayed at the top of this page.

13.2 Where changes are material, 855jl will notify registered players via the email address associated with their account and/or by posting a prominent notice on the platform prior to the changes taking effect.

13.3 Your continued use of the 855jl platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated policy, you should discontinue use of the platform and may request account closure in accordance with our Terms & Conditions.

14.1 855jl has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012. The DPO is responsible for overseeing 855jl's compliance with data protection obligations and serving as the primary point of contact for data subject rights requests and privacy-related inquiries.

14.2 If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us through the following channel:

14.3 When submitting a data subject rights request, please include your full name, registered email address, and a clear description of your request to allow us to process it efficiently. We may need to verify your identity before fulfilling certain requests.

14.4 If you are not satisfied with our response to your privacy inquiry, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.