jlpark Privacy Policy

1 Introduction

1.1 jlpark is committed to protecting the privacy and personal data of all users of the platform, including Filipino players across Metro Manila, Cebu, Davao, and the wider Philippines. This Policy applies to all personal data processed by jlpark in connection with your use of the platform, including through the website, any mobile web interface, customer support interactions, and payment processing.

1.2 jlpark operates as a PAGCOR-regulated online gaming platform. Certain data processing activities are therefore governed not only by this Policy and the Philippine Data Privacy Act (RA 10173), but also by PAGCOR's regulatory requirements, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.

1.3 This Policy should be read alongside jlpark's Terms and Conditions, which govern your use of the platform as a whole.

2 Data Controller Information

2.1 jlpark is the personal information controller responsible for the personal data collected through the jlpark platform. As the controller, jlpark determines the purposes and means of processing your personal information.

2.2 Data Protection Officer (DPO). In compliance with the Data Privacy Act of 2012, jlpark has designated a Data Protection Officer. You may contact the DPO for any data privacy concern at: [email protected]. Please include "Data Privacy Request" in the subject line of your correspondence.

2.3 jlpark is registered with the National Privacy Commission (NPC) of the Philippines as required by the Data Privacy Act and its implementing rules and regulations.

3 Personal Data We Collect

jlpark collects personal data through multiple channels. The categories of data collected include:

3.1 Registration Data: When you create a jlpark account, we collect your legal full name, date of birth (to verify the 21+ age requirement), residential address in the Philippines, email address, mobile phone number (Globe, Smart, or PLDT-affiliated carriers), and chosen username.

3.2 Identity Verification (KYC) Data: To comply with PAGCOR licensing requirements and the Anti-Money Laundering Act, jlpark collects government-issued ID documents for identity verification. Accepted Philippine IDs include: PhilSys National ID, Philippine Passport, Driver's License, SSS or GSIS ID, PRC ID, and Voter's ID. Selfie photographs may be required for liveness verification.

3.3 Financial Data: jlpark collects data related to your GCash account, Maya/PayMaya account, bank account details (BPI, BDO, Metrobank), transaction amounts, deposit and withdrawal history, and source-of-funds declarations where required by AMLA.

3.4 Gaming Activity Data: We record your betting history, game sessions, wagering amounts, win/loss records, bonus claims, and gaming session durations. This data is required by PAGCOR and is used for responsible gaming monitoring and platform improvement.

3.5 Technical Data: IP address, device type, browser type and version, operating system, network provider, login timestamps, session duration, and general geographic location derived from IP data.

3.6 Communications Data: Records of your customer support conversations, emails, and in-platform messages with jlpark staff.

3.7 Cookies and Tracking Data: As described in Section 7 below, jlpark uses cookies and similar technologies to enhance platform functionality. See Section 7 for full details.

4 How jlpark Uses Your Personal Data

jlpark uses the personal data collected for the following purposes:

• Account Management: Creating and administering your jlpark account, processing logins, maintaining your preferences, and managing account security.
• Payment Processing: Processing GCash deposits and withdrawals, Maya transfers, bank transactions, and maintaining accurate financial records of all peso transactions on the platform.
• PAGCOR Regulatory Compliance: Meeting all reporting, audit, and record-keeping obligations required under jlpark's PAGCOR operating license.
• Anti-Money Laundering Compliance: Conducting customer due diligence, monitoring transactions for suspicious activity, and filing reports to the Anti-Money Laundering Council (AMLC) as legally required.
• Responsible Gaming: Monitoring gaming behavior to identify potential problem gambling patterns, enforcing self-exclusion orders, and administering deposit and loss limit settings.
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve game offerings, platform performance, and user experience for Filipino players.
• Customer Support: Responding to your queries, complaints, account issues, and payment concerns.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to users who have opted in. You may opt out at any time via account settings.
• Fraud Prevention and Security: Detecting and preventing fraudulent activity, unauthorized account access, multi-accounting, and other prohibited conduct as defined in jlpark's Terms and Conditions.

5 Legal Basis for Processing

5.1 jlpark processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contract Performance: Processing necessary to operate your jlpark account and deliver the services you have contracted for.
• Legal Obligation: Processing required to comply with PAGCOR's regulatory requirements, AMLA obligations, tax laws, and other Philippine legal obligations applicable to licensed gaming operators.
• Consent: For marketing communications and non-essential cookies, jlpark relies on your explicit consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.
• Legitimate Interest: For fraud prevention, platform security monitoring, and aggregated analytics where these interests are not overridden by your data privacy rights.

6 Sharing Your Personal Data

6.1 jlpark does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly for the purposes described:

• Payment Service Providers: GCash (Mynt), Maya/PayMaya, and Philippine banking partners — to process your financial transactions. These providers process data under their own privacy policies and are bound by data sharing agreements with jlpark.
• PAGCOR: As a PAGCOR licensee, jlpark is required to provide regulatory reports and cooperate with PAGCOR audits and investigations. This disclosure is legally mandated.
• Anti-Money Laundering Council (AMLC): Suspicious transaction and covered transaction reports are filed with AMLC as required by Philippine law.
• Game Technology Providers: Third-party game developers and live dealer providers who power games on jlpark receive limited session and game data necessary to deliver their services. These providers operate under data processing agreements with jlpark.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform monitoring vendors who process data on jlpark's behalf under binding data processing agreements.
• Law Enforcement and Courts: Where legally compelled by valid Philippine court orders, warrants, or law enforcement requests.

6.2 Any third party receiving personal data from jlpark is required to maintain appropriate technical and organizational security measures and to process data only for the specified purpose.

7 Cookies & Tracking Technologies

7.1 jlpark uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies used include:

• Essential Cookies: Required for the platform to function — including maintaining your logged-in session, remembering your game preferences, and ensuring platform security. These cannot be disabled without affecting jlpark's core functionality.
• Analytics Cookies: Used to understand how Filipino players navigate the platform — which games are most visited, where users encounter difficulty, and how to improve the overall experience. Data is aggregated and anonymized.
• Functional Cookies: Remember your language settings, preferred payment method, and other customizations to improve your jlpark experience.
• Marketing Cookies: Used only with your consent to deliver relevant promotional content. You may opt out of marketing cookies via the cookie preference center accessible on the platform.

7.2 You may control non-essential cookies through your browser settings or jlpark's cookie preference center. Note that disabling essential cookies will impair your ability to use the jlpark platform.

8 Data Retention

8.1 jlpark retains personal data for as long as necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods:

• Account and KYC Data: Retained for a minimum of 5 years following account closure, as required by PAGCOR's licensing conditions and AMLA obligations.
• Transaction Records: Financial transaction records are retained for a minimum of 5 years in compliance with Philippine tax and anti-money laundering laws.
• Gaming Activity Data: Retained for a minimum of 3 years for responsible gaming monitoring and PAGCOR audit purposes.
• Communications Data: Customer support records retained for 2 years following the resolution of the relevant support interaction.
• Marketing Data: Retained until you withdraw consent or for 2 years of account inactivity, whichever comes first.

8.2 Following the applicable retention period, jlpark will securely delete or anonymize personal data so that it can no longer be linked to an identifiable individual.

9 Data Security Measures

9.1 jlpark implements technical and organizational security measures appropriate to the risks associated with processing personal data on a PAGCOR-regulated financial platform:

• 256-bit SSL/TLS encryption for all data in transit between user devices and jlpark servers
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records
• Multi-factor authentication (MFA) for administrative access to jlpark's backend systems
• Intrusion detection and real-time security monitoring by qualified cybersecurity personnel
• Strict role-based access controls — staff access personal data only to the extent required for their specific function
• Regular security audits and vulnerability assessments conducted by third-party security firms
• Data breach response procedures aligned with the NPC's mandatory breach notification requirements

9.2 In the event of a personal data breach that poses a real risk of serious harm to data subjects, jlpark will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected users without undue delay.

10 Your Rights as a Data Subject

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by jlpark:

• Right to be Informed: The right to know what personal data jlpark holds about you and how it is used — satisfied by this Policy.
• Right of Access: The right to request a copy of the personal data jlpark holds about you.
• Right to Rectification: The right to correct inaccurate or incomplete personal data. Account details can be updated via jlpark account settings; KYC data corrections require supporting documentation.
• Right to Erasure: The right to request deletion of your personal data where jlpark no longer has a lawful basis to retain it. Note that mandatory retention periods under PAGCOR and AMLA regulations may override this right for certain data categories.
• Right to Object: The right to object to processing based on legitimate interest, including direct marketing. Marketing communications may be opted out at any time.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format for transfer to another controller.
• Right to Damages: The right to claim compensation for any harm suffered as a result of inaccurate, incomplete, outdated, or unlawfully processed personal data.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

10.2 To exercise any of these rights, contact jlpark's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." jlpark will respond within 15 business days of receiving a valid request.

11 Children's and Minors' Privacy

11.1 jlpark's services are strictly restricted to individuals who are 21 years of age or older in accordance with Philippine gaming law and PAGCOR requirements. jlpark does not knowingly collect personal data from persons under 21 years of age.

11.2 If jlpark discovers that personal data has been collected from a person under 21 years of age, the associated account will be immediately closed, all data will be deleted to the extent permitted by applicable law, and any deposited funds will be returned to the source payment method.

11.3 Parents and guardians who believe their child has registered on jlpark should contact [email protected] immediately.

12 International Data Transfers

12.1 jlpark primarily stores and processes personal data within the Philippines. Where data is transferred to service providers located outside the Philippines — for example, cloud infrastructure providers or game technology partners — jlpark ensures that such transfers are subject to appropriate safeguards including standard contractual clauses and data processing agreements that require the recipient to maintain data protection standards equivalent to those required under Philippine law.

12.2 All international data transfers are conducted in accordance with the National Privacy Commission's rules on cross-border data transfers.

13 Updates to This Privacy Policy

13.1 jlpark may update this Privacy Policy periodically to reflect changes in data processing practices, regulatory requirements, or platform features. The revised Policy will be posted on the jlpark platform with an updated "Last Updated" date.

13.2 For material changes that significantly affect how jlpark processes your personal data, registered users will be notified by email or in-platform notification at least 7 days before the changes take effect, where practicable.

13.3 Continued use of jlpark after the effective date of a revised Policy constitutes your acknowledgment of the updated terms. If you do not agree with the revised Policy, you should close your jlpark account.

14 Contact Information & DPO

14.1 For all data privacy concerns, access requests, correction requests, deletion requests, or complaints about jlpark's data processing practices, please contact jlpark's Data Protection Officer:

14.2 If you are dissatisfied with jlpark's response to a data privacy request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the regulatory authority responsible for enforcing the Data Privacy Act.

14.3 jlpark's registration details with the NPC and PAGCOR licensing information are available upon written request to the Data Protection Officer at the contact address above.