Privacy Policy

1 Scope & Introduction

1.1   This Privacy Policy is published by jll3, the operator of jll3.vip ("jll3," "we," "us," or "our"). It governs the collection, processing, use, storage, and disclosure of personal data obtained from individuals ("you," "the Player") who access or use the jll3 Platform and related Services.

1.2   jll3 is committed to processing personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and all applicable issuances of the National Privacy Commission (NPC).

1.3   This Privacy Policy applies to all personal data collected through:

• The jll3.vip website and all associated subdomains and mobile-optimized interfaces;
• The Account registration and KYC verification process;
• Deposit, withdrawal, and all payment-related transactions;
• Customer support interactions — live chat, email, and any other communication channel;
• Promotional participation, surveys, and voluntary data submissions;
• Automated data collection via cookies, server logs, and analytics tools.

1.4   This Privacy Policy should be read in conjunction with jll3's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies, or could reasonably be used to identify, a natural person, directly or indirectly — including name, contact details, identification documents, payment information, device identifiers, and behavioral data.
• "Sensitive Personal Data" means personal data relating to an individual's race, ethnic origin, religion, health, financial standing, government-issued identification numbers, or criminal records — as defined under the Philippine Data Privacy Act.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure, combination, restriction, erasure, or destruction.
• "Data Controller" means jll3, the entity that determines the purposes and means of processing personal data.
• "Data Processor" means a third party that processes personal data on behalf of jll3 under a written data processing agreement.
• "Platform" means jll3.vip, all subdomains, and all software through which jll3 Services are delivered.
• "NPC" means the National Privacy Commission of the Philippines.

3 Personal Data We Collect

3.1   jll3 collects the following categories of personal data, depending on your interaction with the Platform:

3.2   jll3 does not knowingly collect biometric data beyond the document photography required for KYC identity verification purposes.

3.3   Where you choose not to provide personal data that is mandatory for a specific purpose (such as identity verification for withdrawals), jll3 may be unable to provide the relevant Service until the required data is supplied.

4 How We Use Your Personal Data

4.1   jll3 uses the personal data it collects for the following purposes:

• Account registration and management — creating, maintaining, and securing your jll3 Account;
• Identity and age verification (KYC) — verifying that you meet the 21+ eligibility requirement and that your identity matches your registration information;
• Payment processing — facilitating deposits, withdrawals, and all financial transactions in PHP through supported payment methods including GCash, Maya, BPI, BDO, Metrobank, USDT TRC20, and Coins.ph;
• Service delivery — enabling access to live dealer games, slots, sports betting, bingo, and all other jll3 gaming products;
• Customer support — addressing account queries, complaints, technical issues, and general assistance;
• Legal compliance — meeting anti-money laundering (AML) obligations, regulatory reporting requirements, and other legal duties applicable to jll3's operations;
• Responsible gaming — monitoring gameplay patterns for signs of problem gambling; applying deposit limits, session controls, and self-exclusion as requested or required;
• Fraud prevention and security — detecting, investigating, and preventing fraudulent activity, unauthorized Account access, and abuse of Platform features;
• Platform improvement — analyzing aggregated and anonymized usage data to improve game selection, user experience, and Platform performance;
• Marketing communications — where you have provided consent or where permitted by applicable law, sending promotions, bonus offers, and Platform updates through your preferred communication channel.

4.2   jll3 does not use personal data to make fully automated decisions that produce significant legal effects on Players, unless required by law or expressly agreed to by the Player with appropriate safeguards in place.

5 Legal Basis for Processing

5.1   jll3 processes personal data on one or more of the following legal bases, as applicable under the Philippine Data Privacy Act:

• Contract performance — processing is necessary to fulfill our obligations to you under the jll3 Terms & Conditions, including Account registration, payment processing, and Service delivery;
• Legal obligation — processing is required to comply with applicable law, including AML regulations, gaming regulations, and data retention requirements;
• Legitimate interests — processing is necessary for jll3's legitimate business interests, including fraud prevention, Platform security, and responsible gaming monitoring, provided such interests are not overridden by your privacy rights;
• Consent — where processing is not covered by the above bases — particularly for certain marketing communications — jll3 will seek your express consent, which you may withdraw at any time without detriment to your Account standing.

6 Data Sharing & Disclosure

6.1   jll3 does not sell, rent, or license your personal data to third parties for their own marketing purposes. Data is shared only in the circumstances described below:

• Payment processors and financial institutions — GCash, Maya, BPI, BDO, Metrobank, USDT TRC20 networks, and Coins.ph receive only the financial data necessary to process your transactions;
• Identity verification service providers — third-party KYC platforms that process identity documents on jll3's behalf under strict data processing agreements;
• Game content providers — live dealer studios and slot game developers may receive pseudonymized session data necessary for game operation and technical support;
• Analytics and fraud detection providers — technical and behavioral data is shared in aggregated or pseudonymized form for Platform security and performance analytics;
• Customer support technology providers — live chat platforms used to deliver 24/7 support operate under data processing agreements with jll3;
• Regulatory and law enforcement authorities — jll3 may disclose personal data to PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities when required by law, court order, or regulatory demand;
• Business successors — in the event of a merger, acquisition, or restructuring, personal data may be transferred to the successor entity, with notice provided to affected Players.

6.2   All third-party Data Processors engaged by jll3 are required to process personal data solely for the purpose for which it was shared, to maintain appropriate security standards, and to comply with applicable data privacy law.

7 Cookies & Tracking Technologies

7.1   jll3 uses cookies and similar tracking technologies on the Platform to enhance functionality, maintain session continuity, and analyze usage patterns. The following categories of cookies are used:

• Strictly necessary cookies — required for the Platform to function. These include session authentication tokens that keep you logged in during an active jll3 session. These cannot be disabled without impacting Platform functionality.
• Functional cookies — store your preferences such as language settings, game lobby filters, and display preferences to improve your jll3 experience across sessions.
• Analytics cookies — collect anonymized data about how Players use the Platform, including pages visited, session duration, and click paths. This data is used in aggregate form to improve Platform design and performance.
• Security cookies — used to detect and prevent fraudulent activity, including bot behavior, unauthorized access attempts, and suspicious session patterns.

7.2   You may manage cookie preferences through your browser settings. Blocking strictly necessary cookies will impair your ability to use the jll3 Platform. Disabling other cookie categories will not prevent you from using core Services but may affect certain personalization features.

7.3   jll3 does not use third-party advertising cookies or cross-site behavioral tracking technologies for the purpose of serving targeted advertisements on external platforms.

8 Data Retention

8.1   jll3 retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law, whichever is longer.

8.2   The following general retention guidelines apply:

• Account and identity data — retained for the duration of the Account relationship and for a minimum of five (5) years following Account closure, in compliance with AML record-keeping obligations under Philippine law;
• Transaction and financial records — retained for a minimum of five (5) years from the date of each transaction;
• KYC documentation — retained for the period required under applicable regulatory obligations, which may extend beyond Account closure;
• Customer support records — retained for a minimum of two (2) years from the date of the last interaction;
• Gameplay data — retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes;
• Marketing preference data — retained until you withdraw consent or close your Account, whichever is earlier.

8.3   When retention periods expire and no further legal obligation requires continued storage, jll3 will securely delete or anonymize the relevant personal data in accordance with its data disposal procedures.

9 Data Security

9.1   jll3 implements and maintains appropriate technical and organizational security measures to protect personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your browser and the jll3 Platform;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Role-based access controls ensuring that only authorized personnel access personal data on a need-to-know basis;
• Multi-factor authentication for administrative and operational system access;
• Regular security audits, vulnerability assessments, and penetration testing;
• Incident response procedures for the detection, containment, and notification of personal data breaches;
• Ongoing staff training on data privacy obligations and information security practices.

9.2   In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jll3 will notify the NPC and affected Players in accordance with the timeframes and procedures prescribed under Philippine data privacy law.

9.3   While jll3 takes all reasonable steps to protect your personal data, no data transmission over the internet can be guaranteed as completely secure. You are responsible for maintaining the security of your own Account credentials.

10 International Data Transfers

10.1   As jll3 engages international technology and service providers — including game content studios, payment processors, and cloud infrastructure providers — personal data may be transferred to and processed in countries outside the Philippines.

10.2   Where personal data is transferred outside the Philippines, jll3 ensures that appropriate safeguards are in place to protect the data, including:

• Entering into data processing agreements with recipient entities that impose data protection obligations equivalent to those applicable under Philippine law;
• Conducting due diligence on recipient entities' data security and privacy practices prior to data transfer;
• Limiting the scope of transferred data to what is strictly necessary for the third party's contracted function.

10.3   By using the jll3 Platform, you acknowledge that your personal data may be transferred internationally in the circumstances described in this section, subject to the safeguards outlined above.

11 Your Data Privacy Rights

11.1   Under the Philippine Data Privacy Act and its implementing rules, you have the following rights with respect to your personal data held by jll3:

11.2   To exercise any of the above rights, please contact jll3 support via live chat or by writing to support@jll3.vip. jll3 will respond to rights requests within the timeframe prescribed under applicable Philippine data privacy law. Requests may be subject to identity verification before they are processed.

12 Children & Minors

12.1   The jll3 Platform is strictly intended for individuals who are 21 years of age or older. jll3 does not knowingly collect personal data from individuals under the age of 21.

12.2   If jll3 becomes aware that personal data has been collected from a person under 21 without the required age verification, jll3 will take immediate steps to delete that data and close the associated Account. Deposits made by individuals found to be under 21 will be refunded in accordance with jll3's responsible gaming procedures.

12.3   If you believe that jll3 has inadvertently collected personal data from an individual under 21, please contact jll3 support immediately so that the matter can be investigated and remediated.

13 Third-Party Links

13.1   The jll3 Platform does not contain links to external third-party websites beyond those inherent in the delivery of licensed game content from contracted providers. Where any such link exists, jll3 is not responsible for the privacy practices, content, or data processing activities of the linked third-party entity.

13.2   jll3 recommends that you review the privacy policy of any third-party service you interact with independently, including payment providers such as GCash and Maya that have their own privacy practices governing how they handle your data on their respective platforms.

14 Updates to This Privacy Policy

14.1   jll3 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or operational requirements. All updates will be published on this page with a revised Effective Date.

14.2   Where a change is material — particularly any change that significantly affects how jll3 uses your personal data or your rights in relation to it — jll3 will provide reasonable advance notice to registered Players via Account notification or the registered email address.

14.3   Your continued use of the jll3 Platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the revised terms. If you do not agree to the revised Policy, you should cease using the Platform and contact support to close your Account.

15 Contact & Privacy Complaints

15.1   For any questions, concerns, data access requests, or privacy complaints relating to this Privacy Policy or jll3's data processing practices, please contact the jll3 Data Protection team:

15.2   jll3 will acknowledge privacy queries within 72 hours and aim to provide a substantive response within fifteen (15) business days, or within the period prescribed by the NPC for formal data subject requests.

15.3   If you are not satisfied with jll3's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC) in accordance with the procedures established under the Data Privacy Act of 2012 and the NPC's rules on complaints handling.