jllll Privacy
Policy

This Privacy Policy ("Policy") describes how GoTech Entertainment ("jllll", "we", "us", "our") collects, processes, uses, stores, and discloses personal data relating to individuals ("you", "your", "data subject") who access or use the jllll Casino platform at jllll.one, including all associated services, customer support channels, and communications.

jllll operates under a PAGCOR license and is subject to the Data Privacy Act of 2012 (Republic Act No. 10173), its implementing rules and regulations, and the applicable issuances of the National Privacy Commission (NPC) of the Philippines. jllll is also subject to the Anti-Money Laundering Act (AMLA) and its amendments, which impose mandatory data collection and retention obligations that interact with the rights described in this Policy.

By registering an account with jllll or continuing to use jllll.one after the effective date of this Policy, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

The data controller responsible for personal data processed in connection with jllll Casino is:

As data controller, jllll determines the purposes and means of processing your personal data. For processing activities conducted by third-party providers on jllll's behalf (such as payment processors, game providers, and identity verification services), those third parties act as data processors under binding agreements with jllll.

jllll collects the following categories of personal data:

jllll collects personal data through the following methods:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, activate responsible gaming tools, or update your account preferences.
• Automatically through platform use — session data, device information, IP addresses, and gameplay activity are collected automatically whenever you access jllll.one.
• From payment processors — when you make a deposit or withdrawal via GCash, PayMaya, BPI, BDO, Metrobank, Visa, or Mastercard, jllll receives transaction confirmation data from your payment provider.
• From identity verification providers — jllll uses third-party KYC and document verification services to confirm the authenticity of government-issued IDs submitted during account verification.
• From game providers — licensed game providers supplying content to jllll may share game session result data with jllll for the purposes of account crediting, dispute resolution, and responsible gaming monitoring.
• From cookies and similar technologies — as described in Section 8 of this Policy.

jllll processes your personal data for the following purposes:

• Creating and maintaining your jllll account.
• Authenticating your identity at login via password and OTP verification.
• Processing deposits, crediting winnings, and executing withdrawal requests.
• Providing access to games and maintaining accurate account balances.
• Delivering customer support through live chat, email, and messaging channels.

• Verifying your age (21+) and identity as required under PAGCOR regulations.
• Complying with Anti-Money Laundering Act (AMLA) obligations, including transaction monitoring and suspicious activity reporting.
• Maintaining records required by PAGCOR's licensing conditions and audit requirements.
• Responding to requests from PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine regulatory authorities.

• Monitoring account activity to identify potential problem gambling indicators.
• Enforcing deposit limits, loss limits, session limits, cool-off periods, and self-exclusions you have activated.
• Maintaining self-exclusion records to prevent access during active exclusion periods.

• Detecting, investigating, and preventing account fraud, identity theft, and unauthorised access.
• Identifying and addressing violations of jllll's Terms and Conditions.
• Maintaining the integrity of games and preventing collusion or exploitation of technical vulnerabilities.

With your consent, jllll may send you promotional communications about bonuses, new games, and platform updates via SMS or in-platform notifications to your registered mobile number. You may withdraw marketing consent at any time by contacting support or updating your notification preferences in your account settings. Withdrawal of marketing consent does not affect the lawfulness of any processing carried out prior to withdrawal.

Under the Data Privacy Act of 2012, jllll processes your personal data on the following legal bases:

jllll does not sell, rent, or commercially transfer your personal data to any third party. jllll discloses personal data only in the following circumstances:

jllll engages third-party service providers who process personal data solely on jllll's behalf and under binding data processing agreements. These include: payment processors (GCash/GXI, Maya Philippines, BPI, BDO, Metrobank, Visa, Mastercard networks); identity verification and KYC service providers; game content providers (including BetterLive and JILI); cloud hosting and infrastructure providers; and fraud prevention and cybersecurity services.

All service providers are contractually prohibited from using your personal data for any purpose other than the specific service they provide to jllll, and are required to implement appropriate security measures.

jllll is legally required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue, and other competent Philippine government authorities when required by law, regulation, court order, or official government request. jllll will disclose only the minimum information necessary to satisfy the relevant legal requirement.

In the event of a merger, acquisition, reorganisation, or sale of all or part of jllll's business assets, personal data held by jllll may be transferred to the acquiring or successor entity. jllll will notify affected players of any such transfer and the applicable privacy policy of the successor entity before the transfer takes effect.

jllll uses cookies and similar browser technologies to operate certain essential platform functions and to improve the user experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged in during your visit. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences — such as language settings and responsible gaming notification preferences — so you don't have to re-enter them each session.
• Analytics Cookies: Collect anonymised data about how players navigate jllll.one to help us improve platform performance and identify technical issues. Analytics data is aggregated and does not identify individual players.
• Security Cookies: Support fraud detection and account security functions, including recognising previously verified devices to reduce unnecessary OTP prompts.

jllll does not use advertising cookies, behavioural tracking cookies, or any cookies that share your data with third-party advertising networks. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair your ability to use jllll.one.

jllll retains your personal data for the minimum period necessary to fulfil the purposes described in this Policy, subject to mandatory retention requirements under Philippine law:

At the end of the applicable retention period, jllll will securely delete or anonymise your personal data in accordance with NPC guidelines. Note that mandatory retention periods under AMLA cannot be waived even upon your request for data deletion.

jllll implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data it holds. These measures include:

• AES-256 encryption for personal data stored in jllll's databases.
• TLS 1.3 encryption for all data transmitted between your device and jllll.one.
• Multi-factor authentication requirements for jllll staff access to player data systems.
• Role-based access controls limiting internal access to personal data to staff with a verified operational need.
• Regular security audits and penetration testing of platform infrastructure.
• Secure destruction protocols for physical and digital records containing personal data.
• Incident response procedures for personal data breaches, including NPC notification processes.

While jllll takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You also have a role in protecting your account — keep your password secure, do not share your OTP codes, and use the jllll account security features described in the platform.

Under the Data Privacy Act of 2012, you hold the following rights as a data subject. You may exercise any of these rights by contacting jllll at [email protected]. jllll will respond to verified requests within 15 business days.

jllll Casino services are strictly restricted to persons aged 21 years and older. jllll does not knowingly collect personal data from individuals under 21 years of age. Age verification is a mandatory step in the account registration and KYC process.

If jllll becomes aware that personal data has been collected from a person under 21 years of age, jllll will promptly close the relevant account, delete the associated personal data to the extent not required for legal reporting purposes, and where applicable report the matter to PAGCOR. If you have reason to believe that a minor is using jllll Casino, please notify jllll immediately at [email protected].

Some of jllll's third-party service providers — including game content providers and cloud infrastructure services — may process personal data on servers located outside the Philippines. Where such transfers occur, jllll ensures that appropriate safeguards are in place to protect your personal data to standards equivalent to those required under RA 10173.

jllll implements standard contractual clauses and data processing agreements with all third-party processors outside the Philippines, requiring them to maintain security and privacy standards consistent with Philippine law. jllll does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing such safeguards.

jllll may update this Privacy Policy from time to time to reflect changes in our data processing practices, new legal requirements, or platform changes. When we make material changes to this Policy, we will notify registered players via the mobile number or notification channel on file at least seven (7) days before the changes take effect.

The current version of this Privacy Policy is always accessible at jllll.one/privacy-policy. The version number and effective date are displayed at the top of this page and in the table of contents sidebar. Your continued use of jllll.one after the effective date of any updated Policy constitutes acceptance of the revised terms.

For any questions, requests, or concerns relating to your personal data or this Privacy Policy, please contact jllll's Data Protection Officer (DPO) or customer support team:

jllll commits to acknowledging all privacy-related enquiries within two (2) business days and to resolving data subject requests within fifteen (15) business days of identity verification. Complex requests — particularly those involving mandatory retention considerations under AMLA — may take up to thirty (30) business days with prior notification to you of the extended timeline.