jll8 Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") is issued by jll8 and applies to all personal information collected from individuals who access or use the jll8 online gaming platform at jll8.club ("Platform"), including registered account holders, visitors browsing the Platform without an account, and individuals who contact jll8 through any customer support channel.

By accessing the Platform, registering an account, or submitting personal information to jll8 through any means, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to the terms of this Policy, you should not access or use the Platform.

This Policy should be read in conjunction with the jll8 Terms & Conditions, which govern your use of the Platform as a whole. In the event of any inconsistency between this Policy and the Terms relating to personal data matters, this Policy shall prevail.

2 Data Controller Identity

For the purposes of the Philippine Data Privacy Act of 2012, jll8 is the personal information controller in respect of all personal data collected through the Platform. As the personal information controller, jll8 determines the purposes for which and the means by which your personal data is processed.

jll8 operates under authorization from the Philippine Amusement and Gaming Corporation (PAGCOR). As a PAGCOR-regulated entity, jll8 is subject to data handling obligations imposed by both the Data Privacy Act and applicable PAGCOR licensing conditions. PAGCOR may, in the exercise of its regulatory functions, require jll8 to provide certain player data in connection with compliance investigations, audits, or enforcement actions.

Contact details for jll8's Data Protection Officer (DPO) are provided in Section 16 of this Policy.

3 Personal Data We Collect

jll8 collects personal data across several categories, depending on the nature of your interaction with the Platform. The following table summarises the main categories of personal data jll8 may collect:

jll8 does not intentionally collect special categories of sensitive personal information (such as health data, religious beliefs, or political opinions) and requests that you do not submit such information voluntarily unless specifically required for a stated purpose.

4 How We Collect Your Data

4.1 Directly From You

jll8 collects personal data directly from you when you register an account on the Platform; complete the KYC identity and age verification process; make a deposit or request a withdrawal; contact jll8 customer support via live chat, email, or any other channel; set responsible gaming limits or update account preferences; or respond to surveys, promotions, or communications from jll8.

4.2 Automatically Through Platform Use

When you access jll8.club, the Platform automatically collects certain technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, browser and device information, the pages you visit on the Platform, the games you play, session duration, and click patterns. This automated collection occurs each time you visit the Platform, regardless of whether you are logged into an account.

4.3 From Third-Party Service Providers

jll8 may receive personal data about you from third-party service providers engaged to perform services on jll8's behalf, including KYC and identity verification providers, payment processors (including GCash and Maya), fraud detection and AML screening services, and game content providers. Data received from these sources is handled in accordance with this Policy and the applicable data sharing agreements jll8 maintains with each provider.

4.4 From Regulatory Authorities

PAGCOR and other Philippine regulatory authorities may share certain player information with jll8 in connection with regulatory compliance, licence conditions, or player protection obligations. jll8 is required to cooperate with such information sharing under its PAGCOR authorisation.

5 How We Use Your Personal Data

jll8 uses your personal data for the following purposes:

• Account Management: Creating, maintaining, and administering your jll8 account; verifying your identity and age; processing login and authentication events; managing account security including OTP issuance and fraud alerts.
• Service Delivery: Providing access to all games and features available on the Platform; processing deposits and withdrawals through your chosen payment method; applying promotional bonuses and processing wagering activities.
• Regulatory Compliance: Verifying that you meet the PAGCOR-mandated minimum age requirement of 21 years; conducting anti-money laundering (AML) and counter-terrorism financing (CTF) screening; meeting reporting obligations to PAGCOR and relevant Philippine authorities; maintaining records required under applicable gaming and financial regulations.
• Responsible Gaming: Administering the deposit limits, session reminders, cool-off periods, and self-exclusion tools available on the Platform; monitoring gaming patterns to identify potential problem gambling behaviours; acting on responsible gaming interventions required under PAGCOR guidelines.
• Customer Support: Responding to account enquiries, complaints, and support requests; resolving disputes relating to bets, transactions, or account activity; conducting investigations into potential Terms breaches or fraudulent activity.
• Platform Improvement: Analysing aggregated and anonymised usage data to improve the Platform's performance, design, and game selection; conducting internal research and analytics; personalising your Platform experience based on game preferences and usage history.
• Security: Detecting and preventing fraud, cheating, collusion, money laundering, and other prohibited conduct; monitoring for unauthorised account access; maintaining the integrity of the Platform's systems and games.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates via SMS or the contact method associated with your account — only where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time via your account settings.

6 Legal Basis for Processing

jll8 processes your personal data only where a lawful basis for doing so exists under the Philippine Data Privacy Act of 2012. The applicable lawful bases for jll8's processing activities are:

• Performance of Contract: Processing necessary to perform the contract between you and jll8 — including account management, payment processing, and game delivery — is carried out on the basis that such processing is required to provide the service you have requested.
• Legal Obligation: Processing necessary to comply with legal obligations imposed by Philippine law — including PAGCOR licence conditions, AML/CTF obligations under Republic Act No. 9160 (as amended), and obligations under the Data Privacy Act itself.
• Legitimate Interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where jll8's legitimate interests in operating a secure and compliant platform do not override your fundamental privacy rights.
• Consent: Processing for marketing communications and certain optional analytics features, where jll8 has obtained your freely given, specific, informed, and unambiguous consent. Consent-based processing may be withdrawn at any time.

7 Sharing Your Personal Data

jll8 does not sell your personal data. jll8 may share your personal information with the following categories of recipients, strictly for the purposes described in this Policy:

7.1 Service Providers (Personal Information Processors)

jll8 engages third-party service providers to perform specific functions on its behalf, including payment processors (GCash/Maya and bank partners), KYC identity verification providers, fraud detection and AML screening services, IT infrastructure and cloud hosting providers, live casino game streaming providers, and customer support platform operators. These processors are permitted to use your data only for the specific purposes for which they have been engaged and are bound by contractual data protection obligations consistent with this Policy.

7.2 Regulatory and Law Enforcement Authorities

jll8 may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts where required to do so by applicable Philippine law, regulatory directive, court order, or in connection with the investigation of suspected criminal activity.

7.3 Business Transfers

In the event that jll8 undergoes a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the acquiring or successor entity as part of that transaction. jll8 will notify affected players of any such transfer that materially affects the handling of their personal data.

8 International Data Transfers

Some of jll8's service providers — including live casino game streaming providers and certain cloud infrastructure operators — may process data in jurisdictions outside the Philippines. Where personal data is transferred outside the Philippines, jll8 ensures that appropriate safeguards are in place to protect your information, including:

• Contractual clauses requiring the recipient to apply data protection standards consistent with Philippine law;
• Transfers to jurisdictions determined by the National Privacy Commission to provide an adequate level of data protection; or
• Other lawful transfer mechanisms recognised under the Implementing Rules and Regulations of the Data Privacy Act.

You may request further information about the safeguards jll8 applies to international transfers by contacting the Data Protection Officer using the details in Section 16.

9 Cookies & Tracking Technologies

9.1 What We Use

jll8 uses cookies, web beacons, pixel tags, and similar tracking technologies on the Platform. These technologies help jll8 operate the Platform correctly, remember your preferences, maintain your login session, detect fraud, and understand how the Platform is used.

9.2 Types of Cookies

• Strictly Necessary Cookies: Required for the Platform to function. These include session cookies that maintain your login state and security cookies that detect fraudulent access. These cannot be disabled without disabling the Platform itself.
• Functional Cookies: Remember your preferences such as language settings, preferred game categories, and responsible gaming settings. Disabling these may reduce Platform functionality.
• Analytics Cookies: Collect aggregated, anonymised data about how visitors use the Platform — which pages are visited, how long sessions last, which games are most popular. This data helps jll8 improve the Platform.

9.3 Managing Cookies

You can control and delete cookies through your browser settings. Please note that disabling strictly necessary cookies will prevent the Platform from functioning correctly, including maintaining your logged-in session. jll8 does not use third-party advertising cookies or share cookie data with advertising networks.

10 Data Retention

jll8 retains your personal data for as long as is necessary for the purposes described in this Policy and to meet applicable legal retention requirements. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your account plus a minimum of 5 years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act's retention obligations.
• Transaction and Gaming Records: Retained for a minimum of 5 years following the transaction date, as required by applicable Philippine financial and gaming regulations.
• KYC Documents: Retained for the duration of your account plus 5 years following account closure or the date of the last transaction, whichever is later.
• Customer Support Communications: Retained for 3 years following resolution of the relevant support interaction or complaint.
• Technical and Analytics Data: Retained for up to 24 months in identifiable form; anonymised aggregated data may be retained indefinitely for statistical purposes.
• Marketing Consent Records: Retained for the duration of the marketing relationship plus 3 years following withdrawal of consent or account closure.

Upon expiry of the applicable retention period, jll8 will securely delete or anonymise your personal data in accordance with its data destruction procedures.

11 Security Measures

jll8 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• Encryption: All data transmitted between your device and jll8 servers is encrypted using TLS (Transport Layer Security). Sensitive stored data — including KYC documents and financial records — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to jll8 staff and service providers with a legitimate need to process it. Role-based access controls and multi-factor authentication are required for all internal system access.
• Intrusion Detection: jll8 operates automated systems to monitor for unauthorised access attempts, unusual login patterns, and potential data exfiltration events.
• Penetration Testing: jll8's systems undergo regular security assessments and penetration testing by qualified security professionals.
• Staff Training: All jll8 personnel with access to personal data receive mandatory data privacy and security training as part of their onboarding and on a periodic basis thereafter.

12 Your Data Rights Under Philippine Law

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in respect of personal data held by jll8:

To exercise any of these rights, please contact jll8's Data Protection Officer using the details in Section 16. jll8 will respond to verified requests within 15 business days in accordance with NPC guidelines. Requests may require identity verification before jll8 can process them. If you are not satisfied with jll8's response, you have the right to lodge a complaint with the National Privacy Commission.

13 Children & Minors

The jll8 Platform is strictly intended for individuals aged 21 years and above. This is a mandatory PAGCOR regulatory requirement, not merely a terms of service condition. jll8 does not knowingly collect personal data from persons under the age of 21.

As part of the KYC identity verification process, jll8 verifies the age of all Players before enabling withdrawals. If jll8 discovers or has reason to believe that an account has been registered by or is being used by a person under 21 years of age, jll8 will immediately suspend that account, forfeit any balance within it, and delete the associated personal data to the extent permitted by applicable law and regulatory record-keeping requirements.

14 Third-Party Links

The jll8 Platform may contain links to third-party websites — for example, links to payment service providers or regulatory authority pages. This Policy applies only to the jll8 Platform. jll8 is not responsible for the privacy practices or content of any third-party website. When you navigate away from jll8.club to a third-party site, that site's own privacy policy governs the collection and use of your data.

jll8 recommends that you review the privacy policy of any third-party site you visit before submitting personal information to it.

15 Amendments to This Policy

jll8 may update this Privacy Policy from time to time to reflect changes in its data processing practices, applicable law, or PAGCOR regulatory requirements. Where amendments are material — meaning they significantly affect how jll8 collects or uses your personal data — jll8 will notify you via the mobile number or email address associated with your account, and will display a prominent notice on the Platform, at least 7 days before the amendments take effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. jll8 recommends that you review this Policy periodically. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the updated Policy.

Previous versions of this Policy are available upon written request submitted to the DPO contact in Section 16.

16 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the personal data jll8 holds about you, please contact jll8's Data Protection Officer: