Privacy Policy – jlbb Online Gaming Platform

01 About This Privacy Policy

This Privacy Policy ("Policy") is issued by jlbb ("jlbb," "we," "us," or "our") and applies to all personal information collected from individuals ("you," "Player," or "User") who visit the jlbb website at jlbb.asia, register an account on the platform, use any jlbb game or service, or otherwise interact with jlbb through any channel.

jlbb is committed to protecting the privacy of Filipino players and all visitors to the Platform. This Policy explains in clear terms what personal data we collect, why we collect it, how we use and protect it, and what rights you have over your information under Philippine law — specifically the Data Privacy Act of 2012 (Republic Act No. 10173, or "DPA") and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC).

This Policy is incorporated by reference into jlbb's Terms & Conditions and should be read together with those Terms. By registering on jlbb or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

02 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, jlbb acts as the Personal Information Controller (PIC) with respect to the personal data of its registered users and platform visitors. As PIC, jlbb determines the purposes and means of processing your personal information collected through the jlbb platform.

jlbb has designated a Data Protection Officer (DPO) who is responsible for overseeing data protection practices, ensuring compliance with the DPA, and serving as the primary point of contact for data subject rights requests and privacy-related complaints. Contact details for the jlbb DPO are provided in Section 15 of this Policy.

03 Personal Data We Collect

jlbb collects the following categories of personal data in connection with your use of the Platform:

3.1 Account Registration Data

• Philippine mobile phone number (serves as your primary account identifier);
• Date of birth (for age verification — must be 21 or above);
• Full legal name (collected during KYC verification);
• Government-issued identification document type and number (e.g., PhilSys, SSS, UMID, Driver's License, Passport);
• Account password (stored in hashed, non-recoverable form — jlbb staff cannot view your password).

3.2 Financial & Transaction Data

• GCash, Maya, or bank account details associated with your deposit and withdrawal transactions;
• Transaction history: deposit amounts, dates, payment methods, transaction reference numbers;
• Withdrawal requests: amounts, destination accounts, processing timestamps;
• Bonus credits received and wagering activity related to promotional offers.

3.3 Gaming Activity Data

• Game sessions played: titles, stakes, outcomes, session duration;
• Betting history across all jlbb game categories (slots, live casino, bingo, mine games, sports betting);
• Responsible gaming settings you have configured: deposit limits, loss limits, session reminders, self-exclusion status.

3.4 Technical & Device Data

• IP address and approximate geographic location at time of login and gameplay;
• Device type, operating system, and browser version;
• Unique device identifiers (used for fraud detection and session management);
• Session logs: login timestamps, session duration, pages visited.

3.5 Communication Data

• Content of support queries, complaints, and feedback submitted to jlbb;
• Records of customer support interactions via chat and email;
• Your communication preferences for promotional and platform notifications.

04 How We Collect Your Data

jlbb collects personal data through the following means:

• Directly from you: When you register a jlbb account, complete the KYC verification process, make deposits or withdrawals, contact jlbb support, or configure your account settings;
• Automatically through platform use: Session data, device data, IP address, and gameplay data are collected automatically when you access and use the jlbb Platform;
• From payment processors: When you deposit or withdraw funds, our payment partners (GCash, Maya, BPI, BDO, Metrobank, and others) share transaction confirmation data with jlbb as necessary to credit your account and verify transactions;
• From identity verification services: Where jlbb uses third-party KYC services to verify the authenticity of government-issued identification documents you submit;
• Through cookies and similar technologies: As described in Section 8 of this Policy.

05 How We Use Your Personal Data

jlbb uses your personal data for the following purposes:

jlbb does not use personal data to make fully automated decisions that produce significant legal effects on Players without human review. Responsible gaming interventions and account compliance flags are reviewed by jlbb's compliance team before action is taken.

06 Legal Basis for Processing

Under the Data Privacy Act of 2012, jlbb relies on the following legal bases for processing your personal data:

• Contractual necessity: Processing required to perform jlbb's obligations under the Terms & Conditions you agreed to at registration — including account management, payment processing, and game access;
• Legal obligation: Processing required to comply with Philippine law — including PAGCOR's online gaming regulations, the Anti-Money Laundering Act (AMLA), and reporting obligations to regulatory authorities;
• Legitimate interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and analytics where such interests do not override your fundamental rights and freedoms;
• Consent: Processing for marketing communications and promotional notifications. You may withdraw consent at any time by adjusting your notification preferences in your jlbb account settings or by contacting support.

07 Data Sharing & Third-Party Disclosure

jlbb does not sell, rent, or trade your personal data to any third party. We share personal data only in the circumstances described below and only to the extent necessary for the identified purpose:

7.1 Service Providers

jlbb engages carefully selected third-party service providers who process personal data on our behalf as Personal Information Processors (PIPs), subject to binding data processing agreements that require them to protect your data to the same standard as jlbb. These include:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, and other licensed payment service providers;
• KYC and identity verification service providers;
• Game content providers (JILI, Evolution Gaming, Pragmatic Play, PG Soft — limited to session data required for game delivery);
• Cloud hosting and infrastructure providers;
• Customer support platform providers.

7.2 Regulatory & Legal Disclosure

jlbb may disclose personal data to Philippine regulatory authorities, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies, where required by applicable Philippine law, court order, or legal process. jlbb will notify affected Players of such disclosure requests where permitted by law.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of jlbb's business, personal data held by jlbb may be transferred to the acquiring entity as part of the transaction. Affected Players will be notified of any change in data controller, and your existing rights under this Policy will continue to apply.

08 Cookies & Similar Tracking Technologies

jlbb uses cookies and similar browser-based technologies to operate and improve the Platform. The following cookie categories are used:

• Strictly Necessary Cookies: Required for core Platform functionality — session management, authentication, security tokens, and basic navigation. These cannot be disabled without breaking the Platform.
• Functional Cookies: Remember your preferences — such as language settings and your last visited game lobby — to improve your experience on return visits.
• Analytics Cookies: Collect anonymized, aggregated data about how Players use the Platform to help jlbb identify performance issues, popular features, and areas for improvement. No individual player is identifiable from analytics data.
• Session Security Cookies: Used to detect and prevent suspicious login behavior, concurrent session abuse, and cross-site request forgery attacks.

jlbb does not use third-party advertising cookies or behavioral profiling cookies that track you across other websites. You can manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will prevent you from logging in to your jlbb account.

09 Data Retention

jlbb retains your personal data for the periods set out below, after which data is securely deleted or anonymized in accordance with jlbb's data retention schedule:

Upon expiry of the applicable retention period, personal data is permanently deleted from all jlbb systems unless a legal hold is in effect due to ongoing regulatory investigation, litigation, or audit.

10 Data Security Measures

jlbb implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security infrastructure includes:

• Encryption in transit: All data transmitted between your device and jlbb's servers is encrypted using TLS 1.2 or higher. HTTPS is enforced across the entire Platform;
• Encryption at rest: Sensitive personal data — including KYC documents, payment details, and password hashes — is encrypted in storage;
• Access controls: jlbb employee access to personal data is strictly limited on a need-to-know basis, with role-based access controls and comprehensive audit logging;
• Two-factor authentication: Available for all player accounts and mandatory for jlbb administrative access;
• Penetration testing: jlbb conducts regular security assessments and vulnerability testing of its Platform infrastructure;
• Incident response: jlbb maintains a documented security incident response plan. In the event of a personal data breach, jlbb will notify the National Privacy Commission and affected Players within 72 hours of discovery, in accordance with NPC Circular 16-03.

While jlbb maintains robust security measures, no online platform can guarantee absolute security. Players are reminded to protect their own account credentials and to report any suspected unauthorized access to jlbb support immediately.

11 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 (RA 10173), jlbb players have the following rights with respect to their personal data. To exercise any of these rights, please contact jlbb's Data Protection Officer using the details in Section 15.

jlbb will respond to all data subject rights requests within thirty (30) calendar days of receipt. Where additional time is required due to request complexity, jlbb will notify you within the initial 30-day period with an explanation and an extended timeline of no more than sixty (60) additional days.

12 Children's Privacy and the 21+ Requirement

The jlbb Platform is strictly intended for adults aged 21 years and above, in compliance with PAGCOR's online gaming regulations and Philippine law. jlbb does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted during the account registration process and may be repeated as part of KYC verification.

If jlbb becomes aware that personal data has been collected from an individual who was under 21 years of age at the time of registration, the account will be immediately closed, all deposited funds will be returned to the original payment source, and all associated personal data will be deleted, except where retention is required by law to document the violation and regulatory reporting.

Parents or guardians who believe their minor child has registered on jlbb should contact jlbb support immediately at [email protected]. jlbb treats such reports with the highest priority and will investigate and resolve all verified reports within 24 hours.

13 International Data Transfers

The jlbb Platform is operated primarily for Philippine users and Philippine data residency is maintained for core account and transaction data. However, certain service providers used by jlbb — including game content providers, cloud infrastructure providers, and KYC verification services — may process data in locations outside the Philippines.

Where personal data is transferred outside the Philippines, jlbb ensures that such transfers are made only to countries or entities that provide an adequate level of data protection, or are subject to appropriate safeguards such as binding data processing agreements that incorporate the National Privacy Commission's standard contractual clauses. jlbb does not transfer personal data to any country where such transfer is prohibited by Philippine law.

14 Changes to This Privacy Policy

jlbb may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, regulatory requirements, or Platform features. We will notify registered Players of material changes by posting a prominent notice on the jlbb Platform and, where practicable, by sending a notification to your registered mobile number.

The date of the most recent revision is displayed at the top of this Policy. We encourage you to review this Policy periodically to stay informed about how jlbb is protecting your personal information. Your continued use of the jlbb Platform following the publication of a revised Policy constitutes your acknowledgment of the changes.

15 Contact Us & Privacy Complaints

For all privacy-related inquiries, data subject rights requests, questions about this Policy, or complaints regarding jlbb's data handling practices, please contact jlbb's Data Protection Officer:

Filing a Complaint with the NPC

If you believe that jlbb has violated your rights under the Data Privacy Act of 2012, or if you are dissatisfied with jlbb's response to a data subject rights request, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines. jlbb will cooperate fully with any NPC investigation.

Please note that the NPC generally requires complainants to have first attempted to resolve the matter directly with the Personal Information Controller (jlbb) before filing a formal complaint. jlbb is committed to resolving all privacy concerns at the first instance through our DPO before escalation becomes necessary.