jll77 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by jll77 ("jll77," "we," "us," or "our") and applies to all personal data collected, processed, stored, and disclosed by jll77 in connection with the operation of its online gaming platform accessible at jll77.app, including all associated mobile and web-based interfaces, customer support channels, and promotional communications.

jll77 is committed to protecting the privacy of every Filipino player and to processing personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its implementing rules and regulations, and the applicable issuances of the National Privacy Commission (NPC). jll77 also processes data in a manner consistent with PAGCOR's data governance requirements applicable to licensed online gaming operators.

By registering a jll77 account or otherwise providing personal data to jll77, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree, please do not provide personal data to jll77 or use its services.

2. Personal Data We Collect

jll77 collects the following categories of personal data, to the extent necessary and proportionate to the purposes described in this Policy:

2.1 Identity and Contact Data

• Full legal name as it appears on a government-issued ID
• Date of birth and gender
• Registered mobile number
• Email address (if provided during registration)
• Residential address (required for KYC verification)
• Government-issued identification numbers (e.g., PhilSys ID, UMID, SSS, TIN)

2.2 Financial Data

• GCash mobile number and account identifiers
• PayMaya, BPI, BDO, Metrobank, or UnionBank account details used for deposits and withdrawals
• Deposit and withdrawal transaction records
• Account balance history and wagering history

2.3 Technical and Usage Data

• IP address and approximate geographic location
• Device type, operating system, and browser details
• Session logs, login timestamps, and authentication records
• Game activity logs, bet history, and game outcomes
• Cookies and similar tracking identifiers (see Section 9)

2.4 Communications Data

• Live chat transcripts with jll77 support agents
• Records of complaints, queries, and dispute correspondence
• Responses to surveys or promotional communications, where provided voluntarily

3. How We Collect Your Data

jll77 collects personal data through the following means:

• Direct provision: When you register a jll77 account, complete KYC verification, make a deposit or withdrawal request, contact customer support, or participate in a promotion.
• Automated collection: Through cookies, web beacons, log files, and similar technologies that record your interaction with the jll77 platform.
• Third-party sources: From payment processors (such as GCash, PayMaya, BPI), identity verification service providers, fraud prevention databases, and, where applicable, credit reference agencies, where permitted by law.
• KYC and compliance providers: Identity and age verification data may be cross-referenced with third-party compliance databases to verify the accuracy of information provided during registration.

4. Legal Basis for Processing

jll77 processes personal data on one or more of the following legal bases as recognized under the Philippine Data Privacy Act:

• Consent: Where you have provided explicit consent, such as for receipt of promotional communications.
• Contract performance: Where processing is necessary to provide the jll77 services you have contracted for, including account management, gameplay, and financial transactions.
• Legal obligation: Where processing is required to comply with applicable laws, including PAGCOR regulations, anti-money laundering obligations, and tax reporting requirements.
• Legitimate interest: Where processing is necessary for the legitimate interests of jll77, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and freedoms.

5. How We Use Your Personal Data

jll77 uses personal data collected from Filipino players for the following purposes:

• To create, verify, and manage your jll77 account, including KYC identity verification.
• To process deposits, withdrawals, and financial transactions through GCash, PayMaya, and other payment channels.
• To provide, maintain, and improve jll77's online gaming services, including bingo, slots, live casino, and sports betting features.
• To detect and prevent fraud, money laundering, underage gambling, and other prohibited activities.
• To comply with PAGCOR regulatory requirements, anti-money laundering laws, and any other applicable Philippine legal obligations.
• To communicate with you about your account, transactions, security alerts, and platform updates.
• To send promotional communications and personalized offers, where you have consented to receive them.
• To provide customer support and resolve complaints or disputes.
• To analyze usage patterns and improve the jll77 platform's performance, security, and user experience.

6. Disclosure of Personal Data to Third Parties

jll77 does not sell your personal data. jll77 may share personal data with the following categories of third parties strictly to the extent necessary for the purposes identified in this Policy:

• Payment processors: GCash (Mynt), PayMaya (Voyager), BPI, BDO, Metrobank, UnionBank, and other payment partners require account identifiers and transaction data to process financial instructions.
• KYC and identity verification providers: Third-party vendors that assist jll77 in verifying the identity, age, and eligibility of players.
• Game providers: JILI, PG Soft, Pragmatic Play, Evolution Gaming, and other licensed game suppliers may receive pseudonymized player identifiers necessary to deliver game content and enforce bet limits.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where jll77 is required by law to disclose information.
• IT and security service providers: Cloud infrastructure, cybersecurity, and fraud detection vendors engaged to support jll77's platform operations under contractual data processing agreements.

All third parties engaged by jll77 are contractually required to process personal data only for the specified purposes, implement appropriate security measures, and comply with applicable Philippine data protection laws.

7. International Data Transfers

Some of jll77's third-party service providers, including certain game content providers and cloud infrastructure vendors, may process personal data outside of the Philippines. Where such transfers occur, jll77 ensures that appropriate safeguards are in place consistent with the requirements of the Philippine Data Privacy Act, including contractual clauses that bind the recipient to standards of protection equivalent to those applicable in the Philippines. jll77 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing such safeguards.

8. Data Retention

jll77 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to any longer retention periods required by law. In general:

• Account registration and KYC data is retained for the duration of the account relationship and for a minimum of five (5) years after account closure, in compliance with PAGCOR and AMLC requirements.
• Financial transaction records are retained for a minimum of seven (7) years following the transaction date, in line with Philippine financial record-keeping obligations.
• Customer support communications are retained for three (3) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records are retained for the period of the consent plus one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification.

9. Cookies and Tracking Technologies

jll77 uses cookies and similar technologies (web beacons, local storage, session tokens) to operate and improve its platform. The types of cookies used include:

• Essential cookies: Required for basic platform functionality, including authentication session management and security controls. These cannot be disabled without impairing the service.
• Functional cookies: Store your preferences, such as language settings and display configurations, to personalize your jll77 experience.
• Analytics cookies: Used by jll77 to understand how the platform is used — which pages are visited, how long sessions last, and where errors occur — to improve platform performance.
• Security cookies: Used to detect and prevent fraudulent login attempts, bot activity, and other security threats.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using jll77, but may affect certain personalization features.

10. Security of Personal Data

jll77 implements a comprehensive set of technical and organizational security measures to protect personal data against unauthorized access, loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and jll77's servers.
• Encryption of sensitive personal data at rest using industry-standard algorithms.
• Multi-factor authentication (MFA) options for player accounts, including two-factor authentication (2FA) via registered mobile number.
• Access controls and role-based permissions limiting employee access to personal data on a need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments of jll77's platform and infrastructure.
• Incident response procedures for prompt containment and notification in the event of a personal data breach.

In the event of a personal data breach that poses a risk to the rights and freedoms of affected players, jll77 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will inform affected players without undue delay, as required by the Philippine Data Privacy Act.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by jll77:

To exercise any of these rights, contact jll77's Data Protection Officer via live chat on the platform or by email at [email protected]. jll77 will respond to verified data subject requests within thirty (30) days. In complex cases, this period may be extended by a further sixty (60) days with notification.

12. Children and Minors

jll77's services are strictly intended for individuals who are at least 21 years of age. jll77 does not knowingly collect personal data from individuals below the age of 21. If jll77 becomes aware that personal data has been collected from an individual below the minimum age, jll77 will take immediate steps to delete the data and close the associated account. Parents or guardians who believe their child's data may have been collected by jll77 should contact support immediately via the live chat on the platform.

13. Changes to This Privacy Policy

jll77 may update this Privacy Policy from time to time to reflect changes in its data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes will be communicated to registered players through their registered contact details and will be posted on the jll77 platform with the updated effective date. Continued use of jll77's services after the effective date of any update constitutes acceptance of the revised Policy.

14. Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or jll77's processing of your personal data, please contact jll77's Data Protection Officer through the following channel:

If you believe your data subject rights under the Philippine Data Privacy Act have been violated and jll77 has failed to adequately address your concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.