jlmm Privacy Policy

01 Introduction

jlmm ("we," "us," or "our") operates the online gaming platform accessible at jlmm.app (the "Platform"). As the operator of this Platform, jlmm acts as the data controller responsible for the personal data of registered users and visitors.

This Privacy Policy describes how jlmm collects, uses, stores, shares, and protects personal data in connection with your use of the Platform. It also explains the rights available to you under applicable data protection law, including the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), and its Implementing Rules and Regulations.

By registering an account on jlmm or continuing to use the Platform, 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 Privacy Policy, you must discontinue use of the Platform immediately.

This Privacy Policy should be read together with jlmm's Terms & Conditions and Responsible Gaming Policy, both of which are available on the Platform and incorporated herein by reference.

02 Data We Collect

jlmm collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include, but are not limited to, the following:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (used to verify you are 21 years of age or older);
• Residential address, including barangay, city or municipality, province, and postal code;
• Email address and mobile phone number;
• Nationality and country of residence.

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys National ID);
• Proof of address documents (e.g., utility bills, bank statements, barangay certificate);
• Selfie or liveness verification images submitted during the KYC process;
• Source of funds declarations where required by anti-money laundering regulations.

2.3 Financial Data

• Payment method details, including GCash mobile number, PayMaya account reference, BPI or BDO account name, and card details (card number is never stored in full — only the last four digits and card type are retained);
• Transaction history, including deposit amounts, withdrawal requests, and processing dates;
• Bonus and promotional credit history.

2.4 Gaming Activity Data

• Game session logs, including games played, wager amounts, win/loss outcomes, and session duration;
• Responsible gaming settings you have applied to your account, such as deposit limits or self-exclusion status;
• Bonus usage and wagering progress records.

2.5 Technical & Usage Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, browser type and version;
• Pages visited, features accessed, and time spent on the Platform;
• Referral source and marketing attribution data;
• Cookie identifiers and session tokens (see Section 7 for full cookie details).

2.6 Communications Data

• Records of your communications with jlmm's support team, including live chat transcripts, email correspondence, and support ticket history;
• Survey responses and feedback you voluntarily submit.

03 How We Collect Your Data

jlmm collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a promotion;
• Automatically — through cookies, web beacons, and similar tracking technologies when you browse or interact with the Platform (see Section 7);
• From third-party service providers — including identity verification partners, payment processors (such as GCash, PayMaya, BPI, BDO, and card networks), fraud detection services, and analytics providers, where such sharing is necessary to deliver our services;
• From regulatory or law enforcement authorities — where jlmm is legally required to receive or share information in connection with an investigation or compliance obligation.

04 How We Use Your Data

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

jlmm will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis for processing.

05 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, jlmm processes your personal data on the following legal bases:

• Contractual necessity — processing is required to perform our obligations under the Terms & Conditions you have agreed to, including account management, payment processing, and game delivery;
• Legal obligation — processing is necessary to comply with applicable laws and regulations, including anti-money laundering requirements, age verification obligations, and regulatory reporting duties;
• Legitimate interests — processing is necessary for jlmm's legitimate business interests, including fraud prevention, platform security, and service improvement, provided such interests are not overridden by your rights and freedoms;
• Consent — where we rely on your consent as the legal basis for processing (for example, for direct marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

06 Data Sharing & Disclosure

jlmm does not sell, rent, or trade your personal data to third parties for their own 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 protection safeguards:

• Payment processors — GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, to facilitate deposits and withdrawals;
• Identity verification providers — third-party KYC and AML compliance partners who assist with document verification and fraud screening;
• Game software providers — licensed game studios whose titles are hosted on the jlmm Platform, to the extent necessary to deliver gameplay and resolve disputes;
• Analytics and technology providers — service providers who assist with platform performance monitoring, security, and user experience analytics, operating under strict data processing agreements;
• Regulatory and law enforcement authorities — where jlmm is legally required to disclose information, including to PAGCOR or other competent Philippine authorities;
• Professional advisors — lawyers, auditors, and accountants, subject to professional confidentiality obligations;
• Business successors — in the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

07 Cookies & Tracking Technologies

jlmm uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and deliver relevant content. A cookie is a small text file placed on your device when you visit the Platform.

7.1 Types of Cookies We Use

• Strictly necessary cookies — essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without breaking core Platform functionality;
• Functional cookies — remember your preferences such as language settings, responsible gaming limits you have set, and your last visited game category;
• Analytics cookies — collect anonymized data about how players use the Platform, including pages visited and features accessed, to help us improve the user experience;
• Marketing cookies — used to track the effectiveness of our promotional campaigns and to avoid showing you irrelevant offers. These are only placed with your consent.

7.2 Managing Cookies

You can manage your cookie preferences through the cookie consent banner displayed when you first visit the Platform, or at any time through your browser settings. Please note that disabling strictly necessary cookies may prevent you from accessing certain features of the Platform, including your account dashboard and the game lobby.

Most modern browsers allow you to view, delete, and block cookies. For instructions specific to your browser, please refer to your browser's help documentation. Note that clearing cookies will log you out of your jlmm account and reset any locally stored preferences.

08 Data Retention

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

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements;
• Financial transaction records — retained for a minimum of five (5) years from the date of each transaction, as required by Philippine financial regulations;
• Gaming activity logs — retained for three (3) years from the date of each session, or longer if required for dispute resolution or regulatory purposes;
• Support communications — retained for two (2) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution;
• Marketing consent records — retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with jlmm's data disposal procedures. Anonymized data that can no longer be linked to an identifiable individual may be retained indefinitely for statistical and analytical purposes.

09 Data Security

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

• SSL/TLS encryption — all data transmitted between your device and the jlmm Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols;
• Encryption at rest — sensitive personal data stored on jlmm's servers is encrypted using AES-256 encryption;
• Access controls — access to personal data is restricted to authorized jlmm personnel on a strict need-to-know basis, enforced through role-based access control systems;
• Two-factor authentication — available for all player accounts and mandatory for jlmm staff accessing internal systems containing personal data;
• Regular security audits — jlmm conducts periodic penetration testing and vulnerability assessments of its Platform and infrastructure;
• Incident response procedures — jlmm maintains a documented data breach response plan and will notify affected users and the National Privacy Commission (NPC) of the Philippines within the timeframes required by law in the event of a qualifying data breach.

10 Your Rights Under the Data Privacy Act

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jlmm. To exercise any of these rights, please contact our Data Protection Officer at the email address provided in Section 14.

jlmm will respond to all verified data rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with notice provided to you.