Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by JLFun ("JLFun," "we," "us," or "our"), the operator of the online gaming platform accessible at jlfun.one (the "Platform"). This Policy describes how JLFun collects, uses, stores, shares, and protects the personal data of individuals ("you," "your," or "Player") who access or use the Platform.

J LFun is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations ("DPA IRR"), as administered by the National Privacy Commission ("NPC").

This Policy applies to all personal data collected through the JLFun Platform, including data collected via our website, mobile application, customer support channels, and any other means through which you interact with JLFun. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, JLFun acts as the personal information controller in respect of the personal data it collects and processes in connection with the operation of the Platform. This means JLFun determines the purposes and means by which your personal data is processed.

Where JLFun engages third-party service providers to process personal data on its behalf — for example, payment processors, identity verification providers, and cloud hosting services — those parties act as personal information processors and are contractually bound to process your data only on JLFun's instructions and in accordance with applicable data protection law.

If you have any questions about how JLFun processes your personal data, or wish to exercise any of your rights under the DPA, please contact us using the details provided in Section 14 of this Policy.

3 Personal Data We Collect

JLFun collects personal data from you in the following ways: directly from you when you register an account, make a deposit, contact customer support, or participate in a promotion; automatically when you use the Platform; and from third parties such as identity verification services and payment processors.

The categories of personal data we collect include:

JLFun does not knowingly collect full payment card numbers, CVV codes, or online banking credentials. Payment transactions are processed through secure third-party payment gateways, and JLFun receives only a tokenized reference and transaction status confirmation.

4 How We Use Your Personal Data

JLFun uses the personal data it collects for the following purposes:

• Account registration and management: To create and maintain your JLFun account, verify your identity and age (21+ requirement), and manage your account settings and preferences.
• Platform operation: To provide access to games, process bets and payouts, and deliver the core functionality of the JLFun Platform.
• Payment processing: To process deposits and withdrawals in Philippine Peso (₱) via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Regulatory compliance: To fulfill our obligations under Philippine gaming regulations, anti-money laundering laws, and data protection legislation, including reporting obligations to PAGCOR and the AMLC where required.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming patterns, identify indicators of problem gambling, and administer responsible gaming tools such as deposit limits and self-exclusion.
• Platform improvement: To analyze usage patterns, troubleshoot technical issues, and improve the features, performance, and user experience of the JLFun Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time by updating your communication preferences in your account settings.
• Legal proceedings: To establish, exercise, or defend legal claims in connection with the Platform or your account.

JLFun will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, JLFun processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between you and JLFun — specifically, to operate your account, process transactions, and provide access to games on the Platform.
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering obligations, gaming regulatory requirements, and tax reporting obligations.
• Legitimate interests: Processing is necessary for JLFun's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and improving the Platform, provided those interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as sending marketing communications or processing sensitive personal information — JLFun relies on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

JLFun does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals. These providers receive only the data necessary to complete the transaction.
• Identity verification providers: Third-party KYC (Know Your Customer) service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Cloud and hosting providers: Infrastructure and cloud service providers that host the JLFun Platform and store data on JLFun's behalf, subject to strict data processing agreements.
• Analytics providers: Service providers that help JLFun analyze Platform usage and performance. These providers process data in aggregated or pseudonymized form where possible.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government agencies, where disclosure is required by law, court order, or regulatory directive.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers engaged by JLFun in connection with legal proceedings, compliance reviews, or corporate transactions, subject to professional confidentiality obligations.
• Fraud prevention services: Third-party fraud detection and prevention services that help JLFun identify and investigate suspicious activity on the Platform.

Where JLFun shares your personal data with third-party processors, it does so under written data processing agreements that require those processors to implement appropriate technical and organizational security measures and to process your data only on JLFun's documented instructions.

7 Cookies & Tracking Technologies

JLFun uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. They help us keep you logged in, remember your preferences, and understand how you use the Platform.

JLFun uses the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the Platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting Platform functionality.
• Functional cookies: These cookies remember your preferences and settings (such as language and display preferences) to provide a more personalized experience.
• Analytics cookies: These cookies collect information about how you use the Platform — such as which pages you visit most often and how long you spend on each page — to help JLFun improve the Platform. Data collected by analytics cookies is aggregated and does not identify you personally.
• Security cookies: These cookies help JLFun detect and prevent fraudulent activity, including account takeover attempts and bot activity.

JLFun does not use cookies to serve third-party advertising or to track your activity across other websites. You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the JLFun Platform, including your ability to log in and access games.

8 Data Retention

JLFun retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering regulations.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 (Republic Act No. 9160, as amended) and applicable PAGCOR regulations.
• Gaming data: Retained for a minimum of three (3) years from the date of the gaming session, for regulatory compliance and dispute resolution purposes.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless a longer retention period is required in connection with an ongoing dispute or legal proceeding.
• Technical and usage data: Retained for up to twelve (12) months from collection, after which it is aggregated or deleted.

Where JLFun is required by law to retain personal data for a longer period, the statutory retention period will apply. Upon expiry of the applicable retention period, JLFun will securely delete or anonymize your personal data in accordance with its data disposal procedures.

9 Data Security

JLFun takes the security of your personal data seriously and implements a range of technical and organizational measures to protect it against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: Personal data transmitted between your device and the JLFun Platform is encrypted using Transport Layer Security (TLS). Sensitive data stored on JLFun's systems is encrypted at rest using industry-standard encryption algorithms.
• Access controls: Access to personal data is restricted to JLFun personnel and authorized third-party processors who have a legitimate need to access it. All access is logged and subject to regular review.
• Password security: Account passwords are stored in hashed form using a strong cryptographic hashing algorithm. JLFun does not store passwords in plain text.
• Vulnerability management: JLFun conducts regular security assessments and vulnerability scans of its Platform and infrastructure to identify and remediate security weaknesses.
• Incident response: JLFun maintains a data breach response plan. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, JLFun will notify the National Privacy Commission and affected individuals in accordance with the requirements of the DPA.

10 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by JLFun:

• Right to be informed: You have the right to be informed about how JLFun collects and processes your personal data. This Policy fulfills that obligation.
• Right of access: You have the right to request a copy of the personal data JLFun holds about you, together with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data JLFun holds about you. You may update certain account information directly through your account settings.
• Right to erasure: You have 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 JLFun's legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data where JLFun relies on legitimate interests as the legal basis for processing, or where your data is being processed for direct marketing purposes.
• Right to data portability: You have the right to receive a copy of the personal data you have provided to JLFun in a structured, commonly used, and machine-readable format.
• Right to withdraw consent: Where JLFun processes your personal data on the basis of your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe JLFun has processed your personal data in violation of the DPA.

To exercise any of the above rights, please contact JLFun using the details provided in Section 14. JLFun will respond to your request within fifteen (15) business days of receipt. In some cases, JLFun may need to verify your identity before processing your request.

11 Children's Privacy

The JLFun Platform is strictly intended for individuals who are 21 years of age or older. JLFun does not knowingly collect personal data from individuals under the age of 21. The 21+ age requirement is a strict legal requirement under Philippine gaming regulations and is enforced through JLFun's account registration and identity verification processes.

If JLFun becomes aware that it has inadvertently collected personal data from an individual under the age of 21, it will take immediate steps to delete that data and close the associated account. If you believe that JLFun may have collected personal data from a minor, please contact us immediately using the details in Section 14.

Parents and guardians are encouraged to monitor the online activities of minors in their care and to use parental control tools to prevent access to online gaming platforms. JLFun supports responsible gaming and takes underage gambling prevention seriously.

12 Cross-Border Data Transfers

JLFun primarily stores and processes personal data within the Philippines. However, some of JLFun's third-party service providers — including cloud hosting providers and analytics platforms — may process data in servers located outside the Philippines.

Where personal data is transferred outside the Philippines, JLFun ensures that appropriate safeguards are in place to protect your data in accordance with the requirements of the Philippine Data Privacy Act of 2012. These safeguards may include:

• Contractual clauses that require the recipient to protect your personal data to a standard equivalent to that required under Philippine law.
• Transfers to countries or organizations that have been assessed as providing an adequate level of data protection.
• Other legally recognized transfer mechanisms as approved by the National Privacy Commission.

By using the JLFun Platform, you acknowledge and consent to the transfer of your personal data to third-party processors located outside the Philippines, subject to the safeguards described above.

13 Updates to This Policy

JLFun reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made to this Policy, JLFun will notify registered players by posting a prominent notice on the Platform and, where practicable, by sending a notification to the email address associated with your account.

The updated Policy will take effect on the date specified in the notice. Your continued use of the JLFun Platform after the effective date of any amendment constitutes your acknowledgment of the updated Policy. We encourage you to review this Policy periodically to stay informed about how JLFun protects your personal data.

The date at the top of this Policy indicates when it was last updated. Previous versions of this Policy are available upon request by contacting JLFun customer support.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or JLFun's handling of your personal data, please contact our Data Privacy team using the details below. All communications must be in English.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. Information about how to file a complaint with the NPC is available on the NPC's official website.

This Privacy Policy was last updated on January 1, 2026. By continuing to use the JLFun Platform after this date, you confirm your acknowledgment of this Policy in full.