jlmm ph Privacy Policy

1. Introduction

This Privacy Policy ("Policy") governs the collection, processing, storage, and disclosure of personal data by jlmm ph ("we," "us," "our," or "Platform") in connection with the operation of the online gaming platform accessible at jlmmph.club. This Policy applies to all registered users, visitors, and persons who interact with jlmm ph in any capacity.

By registering an account on jlmm ph, accessing the jlmm ph login page, making a deposit, or otherwise using the platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy is incorporated into and forms part of the jlmm ph Terms & Conditions.

jlmm ph operates for Filipino players and is designed with the Philippine market in mind. All data practices described in this Policy are intended to align with the expectations and legal entitlements of Filipino users under Philippine law, including protections available to residents of Metro Manila, Cebu, Davao, Quezon City, and all other regions of the Philippines.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, jlmm ph is the Personal Information Controller (PIC) in respect of all personal data collected and processed through the jlmmph.club platform. As PIC, jlmm ph determines the purposes and means of processing your personal data and bears responsibility for ensuring that such processing is lawful, proportionate, and consistent with this Policy.

Contact details for the jlmm ph Data Protection Officer (DPO) are provided in Section 15 of this Policy.

3. Categories of Personal Data We Collect

jlmm ph collects the following categories of personal data from users of the platform:

jlmm ph does not intentionally collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

4. How We Collect Your Data

jlmm ph collects personal data through the following means:

• Direct collection: Information you provide when registering a jlmm ph account, completing KYC verification, making deposits or withdrawals, contacting support, or updating your account profile;
• Automated collection: Technical and activity data collected automatically as you use the jlmm ph platform, including through cookies, web beacons, server logs, and similar technologies (see Section 10);
• Third-party sources: Identity verification data from licensed KYC service providers; transaction confirmation data from payment processors including GCash, PayMaya, BPI, BDO, and Metrobank; fraud and AML screening data from regulatory databases where applicable.

5. Purposes of Processing

jlmm ph processes your personal data for the following specific, legitimate purposes:

• Creating, maintaining, and managing your jlmm ph account;
• Verifying your identity and age (21+ requirement) in compliance with PAGCOR regulatory obligations;
• Processing deposits, withdrawals, and other financial transactions in Philippine Peso;
• Providing access to jlmm ph games, promotions, and platform features following jlmm ph login;
• Complying with anti-money laundering (AML), counter-terrorism financing (CTF), and Know Your Customer (KYC) legal obligations;
• Detecting, investigating, and preventing fraud, cheating, money laundering, and other prohibited activities;
• Administering responsible gaming tools including deposit limits, self-exclusion, and session monitoring;
• Sending transactional communications (account notifications, security alerts, withdrawal confirmations);
• Sending promotional communications about jlmm ph offers and events — only where you have opted in;
• Improving and maintaining the jlmm ph platform through analytics and performance monitoring;
• Resolving disputes and responding to regulatory inquiries or court orders.

6. Legal Basis for Processing

jlmm ph processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to provide the jlmm ph platform services as agreed in the Terms & Conditions — including account management, game access, and payment processing;
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing conditions, AML/CTF obligations, and data retention requirements;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring — where such interests are not overridden by your rights;
• Consent: Processing for direct marketing communications — only where you have provided prior, informed, and freely given consent, which you may withdraw at any time.

7. Data Sharing & Third Parties

jlmm ph does not sell your personal data to third parties. Personal data may be disclosed to the following categories of recipients in specific circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard — for transaction processing purposes;
• KYC and identity verification providers: Licensed third-party verification services used to confirm your identity and age;
• Fraud and AML screening services: Third-party services used to detect suspicious activity, money laundering risks, and sanctioned individuals;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or court order;
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and analytics service providers who process data as Personal Information Processors (PIPs) under written agreements with jlmm ph that require equivalent data protection standards;
• Professional advisors: Legal counsel, auditors, and compliance consultants under binding confidentiality obligations.

All third parties who receive jlmm ph user data are required to process it only for the purposes for which it was shared and in accordance with applicable Philippine data protection law.

8. Data Retention

jlmm ph retains personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law. The following indicative retention periods apply:

• Account and identity data: Retained for the duration of your jlmm ph account and for a minimum of five (5) years following account closure, in accordance with PAGCOR regulatory requirements and AML obligations;
• Transaction and financial records: Retained for a minimum of five (5) years as required under the Anti-Money Laundering Act and related AMLC regulations;
• Support and communication records: Retained for three (3) years from the date of the relevant interaction;
• Marketing preference records: Retained until you withdraw consent or for three (3) years from your last interaction with jlmm ph, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with jlmm ph's data disposal procedures.

9. Data Security

jlmm ph implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jlmm ph platform;
• Encrypted storage of sensitive personal data, including password hashing using industry-standard algorithms;
• Role-based access controls limiting internal access to personal data to authorized personnel only;
• Regular security audits, penetration testing, and vulnerability assessments;
• Two-factor authentication (2FA) options for user accounts and mandatory MFA for internal administrative access;
• Login location monitoring and anomalous access detection systems.

In the event of a personal data breach that is likely to result in risks to your rights and freedoms, jlmm ph will notify affected users and the National Privacy Commission in accordance with NPC Circular No. 16-03 (Breach Notification) within the prescribed timeframes.

10. Cookies & Tracking Technologies

jlmm ph uses cookies and similar tracking technologies to operate and improve the platform. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the jlmm ph login session, account authentication, and platform security. These cannot be disabled without impairing core platform functionality;
• Functional cookies: Store your preferences such as language settings, game lobby view, and responsible gaming tool configurations;
• Analytics cookies: Collect anonymized data about how users interact with jlmm ph — pages visited, session duration, game categories accessed — to improve the platform experience;
• Security cookies: Assist fraud detection and login anomaly monitoring.

jlmm ph does not use third-party advertising or cross-site tracking cookies. You may manage cookie preferences through your browser settings, though disabling strictly necessary cookies will impair your ability to use the jlmm ph platform.

11. Children & Minors

jlmm ph is strictly prohibited to individuals under 21 years of age. jlmm ph does not knowingly collect personal data from minors. If jlmm ph discovers that personal data has been collected from a person under 21, the relevant account will be immediately suspended, all associated data will be deleted, and any deposited funds will be returned through the original payment method subject to verification.

If you believe that a minor has registered a jlmm ph account, please notify us immediately at [email protected].

12. Exercising Your Data Rights

To exercise any of your data rights described at the top of this page (access, rectification, erasure, objection, portability), please submit a written request to jlmm ph at [email protected] with the subject line "Data Rights Request." Your request should include:

• Your full name and registered jlmm ph account username or email address;
• A description of the right you wish to exercise and the specific data concerned;
• A copy of a valid Philippine government-issued ID for identity verification purposes.

jlmm ph will acknowledge your request within three (3) business days and respond substantively within thirty (30) calendar days. Where a request is complex or numerous, jlmm ph may extend this period by a further thirty (30) days, with notification to you of the extension and the reason therefor.

If you are unsatisfied with jlmm ph's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.

13. Cross-Border Data Transfers

Some of jlmm ph's technology infrastructure and service providers may be located outside the Philippines. Where personal data is transferred to recipients in other jurisdictions, jlmm ph ensures that appropriate safeguards are in place — including contractual clauses requiring the recipient to provide an equivalent standard of data protection — as required under Section 21 of the Data Privacy Act of 2012 and applicable NPC guidelines on cross-border data transfers.

jlmm ph does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing the required contractual safeguards.

14. Amendments to This Policy

jlmm ph reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, platform operations, or data processing practices. Where amendments are material, jlmm ph will notify registered users via their registered email address or by prominent notice on the jlmmph.club platform prior to the changes taking effect.

The "Effective Date" displayed at the top of this page indicates the date on which the current version came into force. Your continued use of jlmm ph following notification of an amendment constitutes acceptance of the revised Policy.

15. Contact & Data Protection Officer

For all privacy-related inquiries, data rights requests, or concerns regarding jlmm ph's data processing practices, please contact:

• Data Protection Officer, jlmm ph
• Platform: jlmmph.club
• Email: [email protected]
• Subject line: "Privacy / DPO Inquiry" for faster routing to the data protection team
• Support channel: 24/7 live chat available via the jlmm ph platform

For complaints about jlmm ph's handling of your personal data that are not resolved to your satisfaction through direct contact, you may file a formal complaint with the National Privacy Commission of the Philippines.