JLL99 Privacy Policy – How We Handle Your Personal Data

1 Overview

JLL99 is committed to protecting the privacy and personal data of every person who interacts with the jll99 platform – whether you are a registered member placing bets, a visitor browsing the site, or someone who has contacted our support team. This Privacy Policy explains, in plain language, what personal information jll99 collects, why it is collected, how it is used and stored, and what your rights are under Philippine law.

This policy is drafted in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations. JLL99 acts as the personal information controller for all data collected through the platform. If you are using jll99 from outside the Philippines, please be aware that your data will be processed and stored in accordance with Philippine data protection law.

We have written this policy to be as readable as possible for our Filipino members. Legal documents do not have to be confusing, and we want every kabayan who uses jll99 to clearly understand what happens to their data.

2 Data We Collect

JLL99 collects different categories of personal information depending on how you interact with the platform. Here is a breakdown of what we collect and why:

JLL99 does not collect sensitive personal information (such as health data, religious beliefs, or political affiliations) unless specifically required by law or directly relevant to a support matter you raise with us.

3 How We Collect Your Data

JLL99 collects personal data through several channels, all of which are directly related to your use of the platform:

• Registration form: When you create a jll99 account, you provide your name, contact number, email address, and date of birth.
• KYC verification: When jll99 requires identity verification before processing a withdrawal or as part of compliance, you submit government-issued ID documents.
• Payment transactions: When you deposit or withdraw via GCash, Maya, BDO, BPI, UnionBank, or card, we receive transaction details from the payment provider.
• Betting activity: Every bet you place, every game you play, and every market you access on jll99 is recorded as part of your account's transaction history.
• Device and browser data: Automatically collected when you visit the jll99 website or use the platform, through standard web server logs and analytics tools.
• Customer support interactions: When you contact jll99 support by live chat, email, or any other channel, the content of that communication is recorded for service quality and dispute resolution purposes.
• Cookies and similar technologies: As described in the Cookies section below.

4 How We Use Your Personal Data

JLL99 uses your personal information for specific, legitimate purposes only. Here is how each type of data is put to use:

• Account management: To create, maintain, and secure your jll99 member account, including password resets, OTP verification, and account recovery.
• Service delivery: To provide access to betting markets, process your bets, calculate and credit winnings, and manage your wallet balance in Philippine Peso (₱).
• Payment processing: To facilitate deposits and withdrawals through GCash, Maya, GrabPay, Coins.ph, InstaPay, PESONet, BDO, BPI, UnionBank, and Visa/Mastercard.
• Legal compliance: To meet jll99's obligations under Philippine anti-money laundering (AML) laws, data privacy regulations, and any applicable gaming regulations, including identity verification and transaction monitoring.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Customer support: To respond to your enquiries, resolve disputes, and improve the quality of jll99's support services.
• Platform improvement: To analyze usage patterns and improve the jll99 platform, fix bugs, and develop new features that our Filipino members will find useful.
• Responsible gaming: To monitor betting patterns and reach out to members who may be showing signs of problem gambling, in line with jll99's Responsible Gaming commitments.
• Promotions and communications: To send you information about jll99 promotions, new features, and relevant updates – but only if you have opted in to receive such communications.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, jll99 processes your personal data on the following legal grounds:

• Consent: You give explicit consent when you register for a jll99 account and agree to this Privacy Policy. You can withdraw consent at any time, subject to jll99's legal retention obligations.
• Contractual necessity: Processing required to perform the services you have contracted jll99 to provide – including account management, payment processing, and bet settlement.
• Legal obligation: Processing necessary to comply with Philippine AML laws, gaming regulations, tax obligations, and lawful requests from government authorities.
• Legitimate interests: Processing carried out for jll99's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.

6 Sharing of Personal Data

JLL99 does not sell your personal data. We share it only in the following limited circumstances:

• Payment service providers: GCash, Maya, GrabPay, Coins.ph, and banking partners (BDO, BPI, UnionBank) receive the minimum data necessary to process your transactions. These providers are bound by their own privacy policies and Philippine financial regulations.
• KYC and identity verification partners: Third-party verification services may receive identity documents to assist jll99 in fulfilling its compliance obligations. These providers act as data processors under jll99's instructions.
• Technology and infrastructure providers: Cloud hosting, analytics, and security service providers who process data on jll99's behalf, subject to strict data processing agreements.
• Regulatory and law enforcement authorities: When required by Philippine law, court order, or lawful request from a competent authority, jll99 will disclose relevant data. JLL99 will notify you of such a disclosure where legally permitted to do so.
• Business transfers: If jll99 undergoes a merger, acquisition, or asset sale, your data may be transferred as part of that transaction. Members will be notified before their data becomes subject to a different privacy policy.

7 Data Retention

JLL99 keeps your personal data only for as long as it is necessary for the purposes for which it was collected, or as required by Philippine law. The following general retention periods apply:

• Active account data: Retained for the duration of your membership with jll99 and for a period of five (5) years after account closure, in line with AML record-keeping requirements.
• Transaction and betting records: Kept for at least five (5) years after the transaction date, as required by financial regulations.
• KYC documents: Retained for five (5) years after your last transaction or account closure, whichever is later.
• Support communications: Generally retained for three (3) years unless a longer period is required for an unresolved dispute.
• Technical and usage data: Retained in aggregated, anonymized form for up to two (2) years for analytics and platform improvement purposes.

When retention periods expire, jll99 securely deletes or anonymizes the relevant data so it can no longer be linked to an individual member.

8 Security Measures

JLL99 takes the security of your personal data seriously and has implemented a range of technical and organizational measures to protect it from unauthorized access, loss, alteration, or disclosure. These include:

• HTTPS encryption: All data transmitted between your device and the jll99 platform is encrypted using TLS (Transport Layer Security).
• Secure payment integrations: Financial transactions are processed through certified payment gateways. JLL99 does not store full card numbers or full bank account credentials on its own servers.
• Access controls: Internal access to personal data is restricted to jll99 staff and contractors who require it to perform their specific role. Access is logged and regularly reviewed.
• Two-factor authentication: Available to all jll99 members to add an extra layer of security to account logins.
• Fraud monitoring: Automated systems monitor account activity and flag unusual patterns for review, helping to protect members from unauthorized use of their accounts.

While jll99 takes every reasonable precaution to protect your data, no online platform can guarantee absolute security. Members are encouraged to use strong unique passwords, enable two-factor authentication, and contact jll99 support immediately if they suspect any unauthorized activity on their account.

9 Cookies and Tracking Technologies

JLL99 uses cookies and similar web technologies to make the platform work correctly and to improve your experience. A cookie is a small text file stored on your device when you visit a website. Here is how jll99 uses them:

• Essential cookies: Required for the jll99 platform to function. These include session cookies that keep you logged in while you navigate the site. You cannot disable these without affecting your ability to use jll99.
• Security cookies: Used to detect suspicious activity, prevent cross-site request forgery, and protect the integrity of your session.
• Analytics cookies: Help jll99 understand how members use the platform – which pages are visited most, where users drop off, and how the site performs across different devices and connection speeds. This data is aggregated and anonymized.
• Preference cookies: Remember your settings and preferences (such as language or display preferences) to improve your experience on return visits.

JLL99 does not use third-party advertising cookies or tracking pixels that share your data with external ad networks. You can manage cookie preferences through your browser settings, though disabling essential cookies may affect platform functionality.

10 Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal information held by jll99: