jli99 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") governs the processing of personal data by jli99.cam ("jli99," "we," "us," or "our"), a PAGCOR-licensed online gaming operator incorporated and registered in the Republic of the Philippines. This Policy applies to all personal information collected through our website, mobile applications, customer support channels, and any related services (collectively, the "Platform").

By registering an account, accessing the jli99 Platform, or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing, storage, and disclosure of your personal information as described herein. If you do not agree with this Policy, you must immediately cease using the Platform and refrain from providing any personal information to jli99.

This Policy should be read in conjunction with our Terms & Conditions, which govern the overall use of the jli99 Platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions, the provisions of this Privacy Policy shall prevail with respect to data privacy matters.

2. Data Controller and Contact Information

jli99.cam acts as the data controller for all personal information collected through the Platform. We are responsible for determining the purposes and means of processing your personal data in accordance with applicable Philippine data protection laws and regulations.

Data Protection Officer Contact: For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer at: [email protected]. We will respond to all privacy-related inquiries within fifteen (15) business days of receipt.

3. Personal Information We Collect

3.1 Information You Provide Directly

When you register an account with jli99, we collect the following categories of personal information that you voluntarily provide:

• Identity Information: Full legal name as it appears on government-issued identification, date of birth, gender, nationality, and photograph (if required for verification purposes).
• Contact Information: Residential address, email address, mobile phone number registered with a Philippine telecommunications provider, and alternative contact methods.
• Financial Information: Payment method details including bank account numbers (for bank transfers), GCash or Maya mobile wallet numbers, cryptocurrency wallet addresses, transaction history, deposit amounts, withdrawal requests, and bonus redemptions.
• Identification Documents: Scanned copies or photographs of government-issued identification documents such as Philippine passport, driver's license, UMID, Unified Multi-Purpose ID, national ID, or other valid identification for Know Your Customer (KYC) and anti-money laundering (AML) compliance purposes.
• Communication Data: Records of communications with our customer support team via live chat, email, phone calls, or social media channels, including inquiries, complaints, feedback, and service requests.

3.2 Information Collected Automatically

When you access and use the jli99 Platform, we automatically collect certain technical and usage information through cookies, web beacons, and similar tracking technologies:

• Device Information: Device type, model, operating system, browser type and version, screen resolution, device identifiers (IMEI, Android ID, IDFA), and mobile network information.
• Usage Data: IP address, geolocation data (country, city, approximate coordinates), pages viewed, time spent on pages, click patterns, navigation paths, referral sources, search queries within the Platform, and interaction with promotional content.
• Gaming Activity: Games played, bet amounts, win/loss records, game session durations, favorite games, gameplay patterns, bonus usage, and account balance fluctuations.
• Security and Fraud Prevention Data: Login timestamps, failed login attempts, device fingerprinting data, behavioral analytics, and any information necessary to detect and prevent fraudulent activity, account takeovers, or Terms violations.

3.3 Information from Third-Party Sources

We may receive personal information about you from third-party service providers, including:

• Payment processors (GCash, Maya, banks, cryptocurrency exchanges) confirming transaction authenticity and preventing payment fraud.
• Identity verification services validating the accuracy of information you provided during registration and KYC processes.
• Publicly available databases and sanctions lists for AML compliance screening and politically exposed persons (PEP) checks.
• Marketing and analytics partners providing aggregated demographic and behavioral data to enhance our services (subject to their own privacy policies).

4. Legal Basis and Purposes for Processing Personal Data

4.1 Contractual Necessity

We process your personal information to fulfill our contractual obligations under the Terms & Conditions you agreed to upon registration. This includes:

• Creating and managing your account on the jli99 Platform.
• Processing deposits, withdrawals, and other financial transactions.
• Providing access to casino games, live dealer tables, sports betting markets, and other gaming products.
• Processing bonus claims, promotional offers, VIP rewards, and loyalty program benefits.
• Maintaining accurate account balance records and transaction histories.
• Resolving disputes, investigating complaints, and enforcing our Terms & Conditions.

4.2 Legal Compliance

jli99 processes personal data to comply with legal obligations imposed by Philippine law, PAGCOR regulations, and international AML/CTF (anti-money laundering and counter-terrorism financing) standards:

• Verifying player identity and age to ensure compliance with 21+ age restrictions mandated by PAGCOR.
• Conducting KYC due diligence, enhanced due diligence (EDD), and ongoing monitoring to prevent money laundering, terrorist financing, and other financial crimes.
• Screening against sanctions lists, PEP databases, and adverse media reports as required by law.
• Maintaining records of transactions, identification documents, and communications as required by regulatory record-keeping obligations (typically seven years).
• Reporting suspicious transactions to the Anti-Money Laundering Council (AMLC) and cooperating with law enforcement investigations when legally required.
• Complying with tax reporting obligations under Philippine law.

4.3 Legitimate Interests

We may process personal data based on our legitimate business interests, provided such processing does not override your fundamental rights and freedoms:

• Fraud prevention and detection: Monitoring for unusual betting patterns, collusion, bonus abuse, multiple account creation, payment fraud, and other prohibited activities.
• Platform security: Protecting against unauthorized access, cyberattacks, data breaches, and technical vulnerabilities.
• Customer support: Providing responsive and personalized assistance to resolve your inquiries and technical issues.
• Service improvement: Analyzing usage data to enhance user experience, optimize game performance, and develop new features.
• Marketing and communications: Sending promotional offers, game recommendations, and platform updates to enhance engagement (you may opt out at any time).

4.4 Consent

For certain processing activities not covered by the above legal bases, we will seek your explicit consent. This includes:

• Sending marketing communications via SMS, email, or push notifications (you may withdraw consent at any time through account settings or by contacting support).
• Using cookies and tracking technologies for advertising and analytics purposes beyond what is strictly necessary for Platform functionality (you may manage cookie preferences through your browser settings).
• Sharing personal information with third-party marketing partners for co-branded promotions (only with your express opt-in consent).

5. How We Use Your Personal Information

jli99 uses the personal information we collect for the following specific purposes:

Purpose Category	Specific Uses
Account Management	Registration, authentication, password resets, profile updates, account closure, balance management
Transaction Processing	Deposits, withdrawals, refunds, payment verification, currency conversion, fee calculations
Gaming Services	Game access, bet settlement, win/loss calculations, live dealer interactions, tournament participation
Compliance & Verification	KYC checks, age verification, AML screening, sanctions checks, regulatory reporting
Fraud Prevention	Fraud detection, risk scoring, behavioral analysis, account monitoring, dispute investigation
Customer Support	Inquiry resolution, technical assistance, complaint handling, service feedback
Marketing	Promotional offers, bonus notifications, VIP rewards, personalized recommendations, newsletters
Analytics	Usage analysis, performance optimization, A/B testing, user research, product development

6. Disclosure of Personal Information to Third Parties

6.1 Service Providers and Business Partners

jli99 may share your personal information with carefully selected third-party service providers who assist us in operating the Platform and delivering services to you. These third parties are contractually obligated to protect your data and use it only for the specific purposes for which it was shared. Categories of third-party recipients include:

• Payment Service Providers: GCash, Maya, banks, cryptocurrency exchanges, and payment gateways that process deposits and withdrawals on our behalf.
• Identity Verification Services: Third-party KYC providers that verify the authenticity of identification documents and perform AML screening.
• Game Providers: Software suppliers such as Pragmatic Play, Evolution Gaming, NetEnt, and others who provide casino games, live dealer platforms, and sports betting systems integrated into our Platform.
• Cloud Service Providers: Hosting and infrastructure providers that store and process data on our behalf using secure, encrypted servers.
• Customer Support Platforms: Live chat, email ticketing, and CRM (customer relationship management) systems that enable us to provide efficient customer service.
• Marketing and Analytics Partners: Advertising networks, email marketing platforms, and analytics tools that help us optimize marketing campaigns and understand user behavior (only with your consent for marketing-related sharing).

6.2 Legal Obligations and Regulatory Authorities

We may disclose your personal information to regulatory authorities, law enforcement agencies, courts, and other governmental bodies when required by law or when we believe in good faith that such disclosure is necessary to:

• Comply with court orders, subpoenas, warrants, or other legal processes issued by Philippine or foreign authorities with jurisdiction.
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC) as mandated by Philippine AML laws.
• Cooperate with PAGCOR audits, investigations, and regulatory inquiries to maintain our gaming license.
• Respond to lawful requests from law enforcement investigating fraud, money laundering, cybercrime, or other illegal activities.
• Protect the rights, property, and safety of jli99, our users, and the public.

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets, bankruptcy, or other corporate restructuring involving jli99, your personal information may be transferred to the acquiring entity or successor organization. We will notify you via email and prominent notice on the Platform before your personal data is transferred and becomes subject to a different privacy policy.

6.4 Affiliated Companies

We may share personal information with affiliated companies within our corporate group for purposes of internal administration, consolidated reporting, fraud prevention, and service optimization, provided that all such entities adhere to data protection standards equivalent to those outlined in this Privacy Policy.

7. Data Retention

jli99 retains personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal, regulatory, accounting, and reporting obligations. Specific retention periods include:

• Account Information: Retained for the duration of your active account and for seven (7) years following account closure to comply with PAGCOR record-keeping requirements and potential legal claims.
• Transaction Records: Retained for a minimum of seven (7) years as required by Philippine AML laws and tax regulations.
• KYC and Identification Documents: Retained for seven (7) years after account closure to satisfy regulatory compliance and audit requirements.
• Communications and Support Records: Retained for three (3) years to provide continuous customer service and resolve disputes.
• Marketing Data: Retained until you withdraw consent or for three (3) years from the last interaction, whichever comes first.
• Technical and Usage Logs: Retained for up to two (2) years for security monitoring, fraud detection, and service optimization purposes.

After the applicable retention period expires, personal information is securely deleted or anonymized in accordance with industry best practices and data protection standards. Anonymized data, which cannot be linked back to you, may be retained indefinitely for statistical analysis and research purposes.

8. Data Security Measures

jli99 implements comprehensive technical, organizational, and physical security measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction. Our security framework includes:

• Encryption: All data transmitted between your device and our servers is encrypted using industry-standard SSL/TLS protocols. Sensitive data at rest, including passwords and financial information, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted on a need-to-know basis. Employees, contractors, and service providers are granted access only to the minimum data necessary to perform their specific job functions.
• Authentication: Multi-factor authentication (MFA), strong password requirements, and session timeout mechanisms protect against unauthorized account access.
• Firewalls and Intrusion Detection: Network firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) monitor and block malicious traffic and cyberattacks.
• Regular Security Audits: Third-party security firms conduct regular penetration testing, vulnerability assessments, and code reviews to identify and remediate potential security weaknesses.
• Employee Training: All employees undergo mandatory data protection and cybersecurity training to ensure they understand their responsibilities in safeguarding personal information.
• Incident Response Plan: We maintain a comprehensive data breach response plan to ensure rapid detection, containment, and notification in the unlikely event of a security incident.

While we implement robust security measures, no system is completely immune to security risks. You also have a responsibility to protect your account by using strong, unique passwords, enabling two-factor authentication if available, and immediately notifying us of any suspected unauthorized access.

9. Your Privacy Rights

Under the Data Privacy Act of 2012 and its implementing rules and regulations, you have the following rights regarding your personal information:

• Right to Access: You have the right to request confirmation of whether jli99 is processing your personal data and to obtain a copy of the personal data we hold about you. We will provide this information free of charge upon your first request; subsequent requests may incur a reasonable administrative fee.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal information. You may update most account information directly through your account settings; for other corrections, contact our support team.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, you withdraw consent, or the data was processed unlawfully. This right is subject to legal limitations, particularly where we are required to retain data for regulatory compliance or legal defense purposes.
• Right to Restrict Processing: You may request that we temporarily limit the processing of your personal data in certain circumstances, such as while we verify the accuracy of data you have disputed or assess the legitimacy of a processing activity.
• Right to Data Portability: You have the right to receive personal data you provided to us in a structured, commonly used, and machine-readable format and to transmit that data to another controller where technically feasible.
• Right to Object: You have the right to object to processing of your personal data based on legitimate interests, direct marketing purposes, or for research and statistical purposes. Upon receiving an objection, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.
• Right to File a Complaint: If you believe we have violated your privacy rights, you have the right to file a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with your full name, account username, and a description of your request. We will respond within fifteen (15) business days and may request additional information to verify your identity before processing your request.

10. International Data Transfers

jli99 primarily operates within the Philippines, and your personal information is stored on servers located within Philippine territory. However, some of our service providers and business partners may be located outside the Philippines, which may result in your personal data being transferred to, processed, or stored in foreign jurisdictions.

When we transfer personal data internationally, we ensure that adequate safeguards are in place to protect your information in accordance with Philippine data protection standards. These safeguards may include standard contractual clauses approved by the National Privacy Commission, binding corporate rules, or transfers to countries recognized by Philippine authorities as providing adequate data protection.

11. Cookies and Tracking Technologies

The jli99 Platform uses cookies, web beacons, pixels, and similar tracking technologies to enhance your user experience, analyze Platform performance, and deliver personalized content and advertising. Cookies are small text files stored on your device that allow us to recognize your browser and capture certain information.

Types of Cookies We Use:

• Essential Cookies: Necessary for Platform functionality, account authentication, security, and session management. These cookies cannot be disabled without significantly impairing your ability to use the Platform.
• Performance Cookies: Collect anonymous information about how you use the Platform, including pages visited, time on site, and error messages encountered. This data helps us optimize performance and user experience.
• Functional Cookies: Remember your preferences, language settings, and customization choices to provide a more personalized experience.
• Marketing and Advertising Cookies: Track your browsing activity to deliver targeted advertisements and measure campaign effectiveness. These cookies require your consent and can be disabled through cookie preference settings.

You can manage cookie preferences through your browser settings. However, disabling certain cookies may limit your ability to use some features of the jli99 Platform. For more information about cookies and how to control them, visit www.allaboutcookies.org.

12. Third-Party Links and Services

The jli99 Platform may contain links to third-party websites, social media platforms, payment processors, and other external services. We are not responsible for the privacy practices or content of these third-party sites. This Privacy Policy applies only to information collected by jli99 through our Platform. When you navigate to third-party sites, we encourage you to read their respective privacy policies to understand how they collect, use, and protect your personal information.

13. Children's Privacy

The jli99 Platform is strictly intended for use by individuals who are at least twenty-one (21) years of age, as mandated by PAGCOR regulations governing online gaming in the Philippines. We do not knowingly collect personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a person below the legal age, we will take immediate steps to delete that information and permanently close the associated account. Parents or guardians who believe that a minor has provided personal information to jli99 should contact us immediately at [email protected].

14. Changes to This Privacy Policy

jli99 reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. Material changes to this Policy will be communicated to you via email to the address associated with your account and through prominent notice on the Platform at least thirty (30) days before the changes take effect.

Your continued use of the jli99 Platform following the effective date of any revised Privacy Policy constitutes acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how we protect your personal information. The "Effective Date" at the top of this document indicates when the current version was last updated.

15. Contact Information and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

jli99 Data Protection Officer
Email: [email protected]
Response Time: Within 15 business days

For general inquiries, customer support, or account-related questions, you may also contact us through:

• Live chat support available 24/7 on jli99.cam
• Email: [email protected]

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.