Privacy Policy – jlvs Online Gaming Platform

jlvs ("jlvs," "we," "us," or "our") is the operator of the online gaming platform accessible at jlvs.one and its associated subdomains and mobile interfaces. jlvs operates under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the laws of the Republic of the Philippines, including Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR") promulgated by the National Privacy Commission ("NPC").

For the purposes of the DPA, jlvs acts as the Personal Information Controller (PIC) with respect to all personal data collected from users of the jlvs platform. This Privacy Policy applies to all personal data processed by jlvs in connection with your registration, account use, financial transactions, gaming activity, and all other interactions with the jlvs platform.

jlvs collects personal data that is adequate, relevant, and limited to what is necessary for the purposes set out in this Privacy Policy. The categories of personal data we collect include:

jlvs does not collect sensitive personal information as defined under Section 3(l) of the DPA beyond what is strictly necessary for identity verification and PAGCOR/AMLA compliance purposes.

jlvs collects personal data through the following channels:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or responding to surveys or promotions;
• Automated collection: Technical data collected automatically when you access the jlvs platform, including IP addresses, device identifiers, browser data, and session logs via cookies and similar technologies;
• Third-party sources: Identity verification data from authorized KYC verification service providers; transaction data from payment processors including GCash, Maya, BPI, BDO, Metrobank, and UnionBank; fraud detection data from risk management service providers.

jlvs processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you accepted at registration, including account management, game delivery, payment processing, and customer support;
• Legal obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulatory requirements, Republic Act No. 9160 (Anti-Money Laundering Act) as amended, and NPC data processing obligations;
• Legitimate interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such processing does not override your fundamental rights and freedoms;
• Consent: Processing for optional communications such as promotional emails and SMS notifications, where you have given explicit consent and may withdraw consent at any time.

jlvs uses the personal data we collect for the following purposes:

• To create, verify, and manage your jlvs account and enforce the one-account-per-person policy;
• To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other supported payment methods;
• To deliver gaming services and maintain accurate gaming activity records as required by PAGCOR;
• To verify your identity and age (21+ requirement) in compliance with PAGCOR registration standards;
• To comply with our obligations under Republic Act No. 9160 (AMLA) and report suspicious transactions to the Anti-Money Laundering Council (AMLC) where required;
• To detect, investigate, and prevent fraud, money laundering, and violations of our Terms and Conditions;
• To operate and enforce responsible gaming tools including deposit limits, loss limits, and self-exclusion;
• To communicate with you regarding your account, transactions, security alerts, and, where you have consented, promotional offers;
• To improve the jlvs platform, analyze usage patterns, and optimize the player experience for Filipino users.

jlvs does not sell, rent, or trade your personal data to third parties for their independent marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• Payment processors: GCash (G-Xchange Inc.), Maya (Paymaya Philippines Inc.), BPI, BDO Unibank, Metrobank, UnionBank, and other payment partners, solely for transaction processing purposes;
• KYC and identity verification providers: Third-party verification service providers engaged to conduct identity and age verification;
• PAGCOR: Player activity data and regulatory reports as required under our operating framework;
• Anti-Money Laundering Council (AMLC): Covered and suspicious transaction reports as required under Republic Act No. 9160 as amended;
• Law enforcement authorities: Personal data disclosed in response to a valid court order, subpoena, or lawful request from Philippine law enforcement or regulatory authorities;
• IT and platform service providers: Cloud hosting, cybersecurity, and platform infrastructure providers operating under binding data processing agreements that prohibit independent use of your data.

Some of jlvs's service providers and technology partners operate servers or processing infrastructure outside of the Republic of the Philippines. Where personal data is transferred to a jurisdiction outside the Philippines, jlvs ensures that such transfers are conducted in accordance with Section 21 of the Data Privacy Act of 2012 and the NPC's rules on cross-border data transfers, including the use of standard contractual clauses or other approved transfer mechanisms that provide a level of data protection substantially equivalent to Philippine law.

jlvs does not transfer personal data to jurisdictions that have not been assessed as providing adequate data protection without implementing appropriate safeguards.

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

• Account and identity data: Retained for the duration of your active account plus five (5) years following account closure, as required under PAGCOR recordkeeping obligations;
• Transaction and financial data: Retained for ten (10) years following the transaction date, as required under Republic Act No. 9160 (AMLA) and related AMLC regulations;
• Gaming activity records: Retained for five (5) years as required under PAGCOR regulatory standards;
• Technical and log data: Retained for twelve (12) months from collection, unless required for an ongoing security investigation or legal proceeding.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC guidelines.

jlvs implements technical, organizational, and physical security measures designed to protect your personal data against unauthorized access, disclosure, alteration, destruction, or loss. Security measures include:

• 256-bit SSL/TLS encryption on all data transmissions between your device and jlvs servers;
• One-way cryptographic hashing of account passwords — jlvs staff cannot view your plaintext password;
• Two-factor authentication (2FA) via OTP available to all account holders;
• Role-based access controls limiting staff access to personal data to those with a demonstrated operational need;
• Regular third-party security audits and penetration testing;
• Incident response procedures aligned with NPC breach notification requirements under the DPA.

In the event of a personal data breach that is likely to give rise to a real risk of serious harm to you, jlvs will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, as required under NPC Circular No. 16-03.

jlvs uses cookies and similar tracking technologies to operate and improve the platform. Cookies used by jlvs fall into the following categories:

• Strictly necessary cookies: Required for platform operation — session authentication, login state, and security tokens. Cannot be disabled without impairing platform functionality;
• Functional cookies: Store your preferences such as language settings, responsible gaming limits, and recently played games;
• Analytics cookies: Collect anonymized data about how users interact with the jlvs platform to help us improve the user experience. Data collected is aggregated and not linked to individual user identities.

jlvs does not use third-party advertising or targeting cookies. You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may prevent you from logging in to your jlvs account.

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by jlvs:

• Right to be informed: The right to know what personal data jlvs collects, how it is used, and with whom it is shared — as set out in this Privacy Policy;
• Right of access: The right to request a copy of the personal data jlvs holds about you;
• Right to correction: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure or blocking: The right to request deletion or blocking of personal data that is no longer necessary for the purposes for which it was collected, subject to jlvs's legal retention obligations;
• Right to data portability: The right to receive your personal data in a structured, commonly used format and transmit it to another personal information controller;
• Right to object: The right to object to processing based on legitimate interest, including direct marketing communications;
• Right to damages: The right to claim compensation for damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data.

To exercise any of these rights, submit a written request to jlvs's Data Protection Officer at [email protected]. jlvs will respond to verified requests within fifteen (15) business days. We may request proof of identity before processing rights requests.

The jlvs platform is strictly restricted to individuals who are at least twenty-one (21) years of age. jlvs does not knowingly collect personal data from persons under 21. If jlvs becomes aware that personal data has been collected from a person under 21, such data will be immediately deleted and the associated account permanently closed in accordance with PAGCOR age verification requirements.

Parents and guardians are encouraged to implement device-level parental controls to prevent persons under 21 from accessing the jlvs platform.

jlvs may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or operational procedures. Material changes will be communicated to registered users via email at least seven (7) days prior to the effective date of the revised policy. The "Effective Date" at the top of this page will always reflect the date of the most recent revision. Your continued use of the jlvs platform following the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

For privacy-related inquiries, to exercise your data subject rights, or to report a potential data breach, please contact the jlvs Data Protection Officer:

Email: [email protected]

Platform: jlvs.one

Response Time: Within 15 business days of receipt of a verified request.

If you are not satisfied with jlvs's response to your privacy complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Republic of the Philippines, which has jurisdiction over personal data processing conducted in the Philippines.