jll77 Privacy Policy — How We Protect Your Personal Data

1 Introduction & Identity of the Data Controller

jll77 is the data controller responsible for personal data processed through jll77.org. As a data controller, jll77 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy applies to all personal data collected from Players, prospective Players, and visitors to jll77.org, whether collected through account registration, gameplay, payment transactions, customer support interactions, or general browsing of the jll77 platform. It applies to data collected online and through any jll77 mobile application or progressive web app, where applicable.

By registering a jll77 account, making a deposit, or otherwise using the jll77 platform, you confirm that you have read, understood, and consent to the processing of your personal data as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use jll77.

2 Personal Data We Collect

jll77 collects personal data that is necessary, adequate, and relevant to the purposes for which it is processed. The categories of personal data jll77 collects include:

jll77 does not intentionally collect sensitive personal information as defined under the DPA (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless specifically required for responsible gaming assessments or as mandated by applicable regulation.

3 How jll77 Uses Your Personal Data

jll77 processes your personal data only for specified, legitimate purposes. The primary purposes for which jll77 processes personal data are as follows:

• Account Management: To create, maintain, verify, and administer your jll77 account, including authentication of your identity during jll77 login sessions and enforcement of account security measures such as two-factor authentication;
• Payment Processing: To process deposits via GCash, Maya, BPI, BDO, Metrobank, and other supported payment methods, and to process withdrawal requests to your nominated payment account;
• Regulatory Compliance: To fulfil jll77's obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the DPA — including KYC verification, transaction monitoring, suspicious activity reporting to the Anti-Money Laundering Council (AMLC), and age verification;
• Game Delivery: To operate live casino tables, slot machines, bingo rooms, sports betting, and other game features, and to accurately record and settle game outcomes and payouts;
• Responsible Gaming: To monitor gaming behaviour for signs of problem gambling, enforce deposit limits and self-exclusion arrangements, and administer responsible gaming tools;
• Customer Support: To respond to Player queries, complaints, and requests submitted via live chat or email;
• Security & Fraud Prevention: To detect, prevent, and investigate fraud, money laundering, bonus abuse, multi-accounting, and other prohibited conduct on the jll77 platform;
• Platform Improvement: To analyse aggregated, anonymised usage data in order to improve jll77's platform performance, game selection, user interface, and overall player experience;
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to Players who have opted in to receive such communications. Players may withdraw consent for marketing communications at any time.

4 Legal Basis for Processing

Under the Philippine Data Privacy Act and its Implementing Rules, jll77 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary for the performance of jll77's contract with you — specifically, delivering gaming services, processing payments, and managing your account;
• Legal Obligation: Processing is required to comply with jll77's legal obligations under PAGCOR regulations, the AMLA, and the DPA — including KYC, AML transaction monitoring, and age verification;
• Legitimate Interests: Processing is necessary for jll77's legitimate interests in preventing fraud, securing the platform, improving services, and enforcing these policies, provided such interests are not overridden by your privacy rights;
• Consent: For marketing communications and non-essential cookies, jll77 relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

5 Data Sharing & Disclosure

jll77 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. jll77 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual data protection obligations:

• Payment Processors: GCash (GXI), Maya (Voyager Innovations), banks (BPI, BDO, Metrobank), and other payment service providers — to process deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and anti-fraud service providers engaged to verify Player identities and screen against watchlists;
• Game Software Providers: Licensed game providers whose software powers jll77's casino games — limited to data necessary to operate games and settle outcomes;
• Regulatory Authorities: PAGCOR, the AMLC, the NPC, and other competent Philippine government authorities — where required by law, court order, or regulatory directive;
• Professional Advisers: Legal, accounting, and audit firms engaged by jll77, subject to professional confidentiality obligations;
• IT & Hosting Providers: Cloud infrastructure and technology service providers who host and maintain the jll77 platform — subject to strict data processing agreements.

All third-party service providers engaged by jll77 are required to implement appropriate technical and organisational security measures and to process personal data only on jll77's documented instructions.

6 Data Retention

jll77 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account and identity data: Retained for a minimum of five (5) years from account closure, as required by PAGCOR regulations and the AMLA;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and Bureau of Internal Revenue (BIR) regulations;
• Gaming activity logs: Retained for a minimum of two (2) years from the date of the activity, for dispute resolution and regulatory audit purposes;
• Customer support communications: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained for the duration of the marketing relationship plus three (3) years to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with jll77's data disposal procedures.

7 Cookies & Tracking Technologies

jll77.org uses cookies and similar tracking technologies to operate the platform, authenticate users during jll77 login sessions, remember preferences, and analyse platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without breaking platform functionality;
• Functional Cookies: Used to remember your preferences (e.g., preferred game lobby view, language settings). These improve your experience but are not essential;
• Analytics Cookies: Used to collect anonymised, aggregated data about how Players use jll77 — pages visited, session duration, features used. This data is used solely to improve the platform;
• Security Cookies: Used for fraud detection, bot prevention, and account security monitoring.

You may configure your browser to refuse or delete non-essential cookies. Please note that disabling certain cookies may affect the functionality of the jll77 platform, including jll77 login performance on some browsers.

8 Data Security

jll77 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jll77 platform;
• Encryption of sensitive data at rest, including financial data and identity documents;
• Role-based access controls limiting employee access to personal data to those with a documented need;
• Multi-factor authentication for all jll77 administrative systems;
• Regular security audits, penetration testing, and vulnerability assessments;
• Incident response procedures for detecting, investigating, and reporting personal data breaches in accordance with NPC requirements.

While jll77 takes all reasonable precautions to protect your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the security of your jll77 login credentials and for notifying jll77 immediately if you suspect any unauthorised access to your account.

9 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jll77:

• Right to be Informed: The right to be informed whether jll77 holds personal data about you and how it is being processed — fulfilled through this Privacy Policy;
• Right of Access: The right to request a copy of the personal data jll77 holds about you and information about how it is processed;
• Right to Rectification: The right to request correction of inaccurate, incomplete, or outdated personal data held by jll77;
• Right to Erasure or Blocking: The right to request deletion or suspension of processing of your personal data where it is incomplete, outdated, false, unlawfully obtained, or no longer necessary for the purpose it was collected, subject to jll77's legal retention obligations;
• Right to Data Portability: The right to request that your personal data be provided to you in a structured, commonly used, and machine-readable format;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Damages: The right to be indemnified for any damages sustained as a result of inaccurate, incomplete, outdated, false, or unlawfully processed personal data, in accordance with applicable Philippine law.

To exercise any of these rights, please contact jll77's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request". jll77 will respond to all verified requests within thirty (30) days of receipt, as required under the DPA.

10 Children's Privacy

The jll77 platform is strictly intended for persons who are at least twenty-one (21) years of age. jll77 does not knowingly collect, process, or retain personal data from individuals under the age of 21. If jll77 becomes aware that personal data has been collected from a person under 21 without appropriate age verification, such data will be immediately deleted and the associated account permanently closed. Parents or guardians who believe that a minor has registered or accessed jll77 should contact [email protected] immediately.

11 Third-Party Links

jll77.org does not contain links to external third-party websites. All navigation and content on jll77 is internal to the jll77 platform. To the extent that any third-party game software or payment interface is embedded within jll77 during gameplay or payment processing, such third parties' privacy practices are governed by their own privacy policies. jll77 is not responsible for the privacy practices of third-party game providers or payment processors, though jll77 requires all such parties to maintain data protection standards consistent with Philippine law through contractual obligations.

12 Updates to This Privacy Policy

jll77 may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory requirements, platform features, or data processing practices. Material changes will be communicated to registered Players via the email address or mobile number on record, or through a prominent notice on the jll77 platform, at least seven (7) days before the changes take effect. The "Last Updated" date at the top of this page reflects the most recent revision. Continued use of jll77 following the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes.

13 Contact the jll77 Data Protection Officer

For questions, concerns, complaints, or data subject rights requests relating to this Privacy Policy or jll77's personal data processing practices, please contact jll77's Data Protection Officer:

• Email: [email protected] (subject: "Privacy / DPO Inquiry")
• Live Chat: Available 24/7 via the jll77 platform

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated. The NPC can be contacted via its official website at privacy.gov.ph (note: jll77 does not link to external sites; please access the NPC independently).