jlj2 Privacy Policy

This Privacy Policy (the "Policy") describes how jlj2 (referred to as "jlj2", "we", "us", or "our") collects, uses, stores, discloses, and otherwise processes the personal information of individuals ("Members", "Players", "Users", or "you") who access or use jlj2.club and related services (collectively, the "Platform").

This Policy applies to all personal data collected through the jlj2 website, mobile-optimised browser interface, customer support channels, and any communications between jlj2 and its members. It applies equally to prospective registrants who interact with jlj2.club without completing registration.

By registering for a jlj2 account or using the Platform, you acknowledge that you have read, understood, and consent to the collection and use of your personal data as described in this Policy. If you do not agree, please discontinue use of the Platform immediately.

For purposes of the Philippine Data Privacy Act of 2012, jlj2 is the personal information controller responsible for the personal data collected through jlj2.club.

All data subject requests, privacy enquiries, and complaints may be directed to the jlj2 Data Privacy Officer via the contact details set out in Section 14 of this Policy.

jlj2 collects the following categories of personal data from Members:

jlj2 does not collect sensitive personal information as defined under RA 10173 (e.g., health data, biometric data, political affiliations) unless strictly required for regulatory compliance purposes, in which case explicit consent will be obtained.

jlj2 collects personal data through the following means:

• Direct Submission: Data you actively provide during registration, KYC verification, payment processing, or when contacting jlj2 support.
• Automated Collection: Technical and usage data collected automatically when you access jlj2.club via cookies, web beacons, server logs, and similar technologies (see Section 10).
• Third-Party Payment Providers: Transaction confirmation data shared by GCash, PayMaya, and partner banks when you make deposits or request withdrawals via jlj2.
• Identity Verification Partners: Confirmation data from KYC verification service providers used to validate Philippine government-issued identification documents.
• Regulatory Authorities: In limited circumstances, jlj2 may receive data from PAGCOR or other Philippine regulatory bodies in connection with licensing, compliance reviews, or investigation of player complaints.

jlj2 processes your personal data for the following purposes, each supported by a lawful basis under RA 10173:

• Account Registration and Management — to create and maintain your jlj2 account. Basis: performance of a contract.
• Identity and Age Verification (KYC) — to verify that you meet the 21+ age requirement and comply with PAGCOR regulatory standards. Basis: legal obligation.
• Payment Processing — to process deposits via GCash and PayMaya and withdrawals to your registered Philippine bank or e-wallet. Basis: performance of a contract.
• Fraud Prevention and Security — to detect, investigate, and prevent fraudulent transactions, account abuse, and prohibited activities. Basis: legitimate interests and legal obligation.
• Regulatory Compliance — to fulfil obligations under applicable PAGCOR requirements, the Anti-Money Laundering Act, and other Philippine laws. Basis: legal obligation.
• Customer Support — to respond to enquiries, resolve disputes, and assist with account issues submitted via live chat or email. Basis: performance of a contract and legitimate interests.
• Responsible Gaming — to monitor gameplay patterns for signs of problem gambling and to facilitate self-exclusion or limit requests. Basis: legitimate interests and legal obligation.
• Platform Improvement — to analyse usage patterns, improve platform performance, and personalise game recommendations. Basis: legitimate interests (with opt-out available).
• Marketing Communications — to send promotional offers, bonus notifications, and jlj2 news. Basis: consent (you may withdraw at any time).

jlj2 does not sell your personal data. We share personal data only with the following categories of third parties, and only to the extent necessary for the stated purpose:

• Payment Service Providers: GCash (Mynt/Globe Fintech), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank — for processing deposits and withdrawals.
• KYC and Identity Verification Providers: Accredited third-party services that validate Philippine government-issued IDs as part of the jlj2 registration process.
• Game Content Providers: Third-party studios whose games are hosted on jlj2.club may receive anonymised session data for RTP verification and audit purposes.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies — when required by law or court order.
• IT Infrastructure Providers: Cloud hosting and cybersecurity service providers operating under binding data processing agreements with jlj2.

Some of jlj2's technology service providers and game content partners operate infrastructure located outside the Philippines. Where personal data is transferred internationally, jlj2 ensures that:

• The recipient country or organisation provides an adequate level of data protection equivalent to Philippine standards under RA 10173; or
• Appropriate contractual safeguards (such as standard data processing agreements) are in place between jlj2 and the recipient; and
• The transfer is strictly limited to data necessary for the specific purpose.

Players in Metro Manila, Cebu, Davao, Quezon City, and other Philippine locations can be assured that cross-border transfers involving their jlj2 account data are subject to contractual protections that mirror the requirements of RA 10173.

jlj2 retains personal data for the following periods:

• Active account data — retained for the duration of your jlj2 membership and for five (5) years following account closure, as required for compliance with Philippine financial and gaming regulations.
• KYC and identity documents — retained for a minimum of five (5) years from the date of verification, in line with PAGCOR and AMLC requirements.
• Transaction records — retained for a minimum of five (5) years from the date of each transaction under applicable Philippine anti-money laundering laws.
• Customer support records — retained for three (3) years from the date of the last interaction, or longer if related to an open regulatory matter.
• Technical and usage data — retained for up to two (2) years unless required longer for security investigation purposes.
• Marketing consent records — retained until consent is withdrawn or the account is closed, whichever is earlier.

Upon expiry of the applicable retention period, jlj2 will securely delete or anonymise your personal data.

jlj2 implements appropriate technical and organisational security measures to protect your personal data from unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• TLS (Transport Layer Security) encryption for all data transmissions between your browser and jlj2.club.
• Industry-standard one-way hashing of all account passwords — jlj2 staff have no access to your actual password.
• Role-based access controls limiting internal access to personal data to authorised personnel only, on a need-to-know basis.
• Regular security audits and penetration testing of the jlj2 Platform and its infrastructure.
• Two-factor authentication (2FA) available for all jlj2 accounts to add a second verification layer at jlj2 login.
• Anomaly detection systems that flag unusual login activity (e.g., access from an unrecognised device or location outside the Philippines).

jlj2.club uses cookies and similar tracking technologies to operate the Platform and improve your experience. The types of cookies used include:

• Strictly Necessary Cookies: Required for jlj2 login sessions, security tokens, and basic Platform functionality. These cannot be disabled.
• Performance Cookies: Collect anonymised data on how Members use jlj2.club (pages visited, load times, error rates) to help us improve platform performance.
• Functionality Cookies: Remember your preferences (e.g., preferred language, last visited game category) to personalise your jlj2 experience.
• Analytics Cookies: Used by jlj2's internal analytics tools to understand aggregate user behaviour patterns. No personally identifiable data is shared with external analytics services.

You may configure your browser to reject non-essential cookies. Note that disabling certain cookies may affect the functionality of jlj2.club, including some features of the jlj2 login and account management system.

Under the Philippine Data Privacy Act of 2012, jlj2 Members have the following data subject rights:

• Right to be Informed — you have the right to know that jlj2 is processing your personal data and the purposes for which it is used. This Policy fulfils that obligation.
• Right to Access — you may request a copy of the personal data jlj2 holds about you.
• Right to Rectification — you may request correction of inaccurate or incomplete personal data in your jlj2 account.
• Right to Erasure — you may request deletion of your personal data where jlj2 no longer has a lawful basis for retaining it. Note that certain data must be retained under Philippine law regardless of this request.
• Right to Object — you may object to jlj2 processing your data for marketing purposes at any time.
• Right to Data Portability — you may request that jlj2 provide your personal data in a structured, commonly used format.
• Right to Lodge a Complaint — if you believe jlj2 has violated your data privacy rights, you may file a complaint with the Philippine National Privacy Commission (NPC).

To exercise any of these rights, contact the jlj2 Data Privacy Officer via live chat or email (see Section 14). We will respond to all verified data subject requests within fifteen (15) business days.

If jlj2 becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account and delete the data. If you believe a minor has accessed jlj2.club, please notify our support team immediately.

jlj2 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform features. When material changes are made, jlj2 will notify registered Members via the email address on file or via an in-platform notification visible upon next jlj2 login.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Continued use of jlj2.club after the effective date of any changes constitutes your acceptance of the revised Policy.

For all privacy-related enquiries, data subject requests, or complaints regarding jlj2's handling of your personal data, please contact:

• Data Privacy Officer, jlj2
• Live Chat: Available 24/7 via jlj2.club — select "Privacy / Data Request" from the support menu
• Email: [email protected] (plain text — not a clickable link)

If your concern is not resolved to your satisfaction after contacting jlj2, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines, the independent regulatory body responsible for enforcing RA 10173.