Privacy Policy

1. Who We Are

This Privacy Policy is issued by jl 4 ("jl 4," "we," "us," or "our"), the operator of the online gaming platform accessible at jl-4.app. jl 4 is the data controller responsible for the personal data of players and visitors who use the Platform.

This Privacy Policy applies to all personal data collected through the jl 4 website, mobile applications, customer support channels, and any other touchpoints through which you interact with jl 4. It should be read together with our Terms & Conditions and Responsible Gaming Policy.

jl 4 is committed to protecting the privacy and personal data of all players in the Philippines in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC).

2. Personal Data We Collect

jl 4 collects the following categories of personal data from players and Platform visitors:

jl 4 does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for identity verification, age verification, or compliance with anti-money laundering regulations. Where such data is collected, it is handled with the highest level of care and protection.

3. How We Collect Your Data

jl 4 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs. See Section 7 for more information on cookies.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from GCash, PayMaya, and banking partners in connection with your transactions.
• Publicly available sources: Information from public databases or social media profiles where relevant to fraud prevention or regulatory compliance.

4. How We Use Your Personal Data

jl 4 uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your jl 4 account, including processing your registration and verifying your identity and age.
• Service delivery: To provide you with access to games, process deposits and withdrawals, apply bonuses, and deliver the core gaming experience.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Regulatory compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) requirements, PAGCOR regulations, and the Data Privacy Act.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling.
• Marketing and promotions: To send you information about jl 4 promotions, bonuses, and new features, where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the Platform.
• Legal proceedings: To establish, exercise, or defend legal claims involving jl 4.

5. Legal Basis for Processing

jl 4 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your account and deliver gaming services.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations and PAGCOR licensing requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

jl 4 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification services used to verify your identity and comply with regulatory requirements.
• Fraud prevention partners: Anti-fraud and security service providers who assist jl 4 in detecting and preventing fraudulent activity.
• Game providers: Third-party game studios and live dealer operators whose games are available on the jl 4 Platform, to the extent necessary to deliver those games.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where required by law or regulatory obligation.
• Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by jl 4 in connection with legal proceedings or compliance matters.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of jl 4's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

7. Cookies & Tracking Technologies

jl 4 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. Cookies are small text files stored on your device when you visit the Platform.

jl 4 uses the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and game display options, to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how players use the Platform, helping jl 4 identify areas for improvement. Used only with your consent.
• Marketing cookies: Track your activity to deliver relevant promotional content. Used only with your explicit consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no consent is required as they are essential to service delivery.

8. Data Retention

jl 4 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general rule, jl 4 retains account and transaction data for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations and PAGCOR record-keeping requirements. Gaming history and financial transaction records may be retained for longer periods where required by applicable law.

Marketing data is retained until you withdraw your consent or opt out of marketing communications. Technical and usage data collected through cookies is retained for shorter periods as specified in our cookie settings.

When personal data is no longer required, jl 4 will securely delete or anonymize it in accordance with our data retention and disposal procedures.

9. Data Security

jl 4 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the jl 4 Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Access controls limiting personal data access to authorized personnel on a need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Multi-factor authentication options for player accounts;
• Continuous monitoring for suspicious activity and potential data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl 4 will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act and NPC Circular No. 16-03.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl 4:

• Right to be informed: The right to know what personal data jl 4 collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data jl 4 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jl 4's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact jl 4's Data Protection Officer via the contact details in Section 13. jl 4 will respond to all data rights requests within thirty (30) days of receipt, in accordance with NPC guidelines.

11. Children's Privacy

The jl 4 Platform is strictly intended for persons aged 21 years and above. jl 4 does not knowingly collect personal data from individuals under the age of 21. If jl 4 becomes aware that personal data has been collected from a person under 21, the account will be immediately suspended, the data will be deleted, and any deposited funds will be returned to the payment source.

If you are a parent or guardian and believe that a minor has registered an account on jl 4, please contact our support team immediately so that we can take appropriate action.

12. Changes to This Privacy Policy

jl 4 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. When material changes are made, jl 4 will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when the Privacy Policy was most recently revised. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. We encourage you to review this page periodically to stay informed of how jl 4 protects your personal data.

13. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by jl 4, please contact our Data Protection Officer (DPO):

Email: [email protected]

You may also reach our general support team at [email protected] or via the 24/7 in-platform live chat.

For complaints that cannot be resolved directly with jl 4, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.