jll55 Privacy
Policy

1.1 This Privacy Policy (the "Policy") is issued by jll55 ("jll55," "we," "us," or "our") and governs the collection, use, storage, disclosure, and protection of personal data processed in connection with the jll55 online gaming platform accessible at jll55.org (the "Platform").

1.2 jll55 acts as a personal information controller under Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines ("DPA"), and its Implementing Rules and Regulations ("IRR"). We process personal data only for lawful purposes, with adequate safeguards in place to protect the privacy and security of every Member and visitor.

1.3 This Policy applies to:

• Registered Members of the jll55 Platform, including all individuals who have submitted personal data during the account registration process;
• Individuals who visit jll55.org without registering an account;
• Individuals who contact jll55 via any support channel.

1.4 This Policy should be read in conjunction with the jll55 Terms & Conditions and Responsible Gaming Policy, all of which together constitute the full framework of rights and obligations applicable to jll55 Members.

2.1 For the purposes of the DPA, the personal information controller responsible for your data is jll55, operator of the gaming platform at jll55.org.

2.2 All data protection inquiries, requests to exercise data subject rights, and complaints relating to the processing of your personal data by jll55 should be directed to our designated Data Protection Officer (DPO) via the contact details set out in Section 16 of this Policy.

3.1 jll55 collects the following categories of personal data in connection with the operation of the Platform:

3.2 jll55 does not collect sensitive personal information as defined under Section 3(l) of the DPA (including racial or ethnic origin, political beliefs, health data, or biometric data) except where expressly required for identity verification purposes and with the Member's explicit consent.

4.1 Directly from you. jll55 collects personal data that you provide directly, including during account registration, when completing identity verification, when contacting customer support, when submitting deposit or withdrawal requests, and when updating your account profile or responsible gaming settings.

4.2 Automatically during Platform use. When you access and use the jll55 Platform, we automatically collect technical and usage data through server logs, session tracking technologies, and analytics tools. This includes your IP address, device identifiers, game session data, and navigation patterns within the Platform.

4.3 From third-party service providers. jll55 may receive personal data from third parties in limited circumstances, including:

• Payment processors (GCash, PayMaya, banks) for the purpose of verifying transaction authenticity and preventing fraud;
• Identity verification service providers engaged to assist with KYC compliance;
• Software providers for game session logs and integrity monitoring.

4.4 In all cases, jll55 ensures that third parties from whom we receive personal data have collected that data lawfully and with appropriate authority to share it with us.

5.1 jll55 processes personal data for the following specified, legitimate, and proportionate purposes:

1. Account creation and management — to register, verify, and maintain your jll55 Account, and to authenticate your identity on login;
2. Platform service delivery — to provide access to games, process wagers, manage your Balance, and deliver all features of the Platform;
3. Payment processing — to process deposits and withdrawals via GCash, PayMaya, bank transfer, and card channels, and to maintain accurate transaction records;
4. Identity and age verification (KYC) — to verify that you meet the 21+ age requirement and to comply with applicable anti-money laundering and counter-terrorism financing obligations;
5. Fraud prevention and security — to detect, investigate, and prevent unauthorized access, fraudulent activity, money laundering, and abuse of the Platform;
6. Responsible gaming compliance — to enforce deposit limits, loss limits, self-exclusion periods, and other responsible gaming tools that you activate from your Account;
7. Customer support — to respond to your inquiries, manage support tickets, and improve the quality of our support services;
8. Legal and regulatory compliance — to comply with applicable Philippine laws and regulations, including the DPA, the Anti-Money Laundering Act, and PAGCOR's regulatory requirements;
9. Platform improvement and analytics — to understand how Members use the Platform and to improve features, user experience, and performance, using aggregated and where possible anonymized data;
10. Marketing communications — to send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications.

5.2 jll55 does not process personal data for purposes incompatible with those listed above without first obtaining your consent or establishing a separate lawful basis.

6.1 jll55 processes personal data on the following legal bases under the DPA:

• Consent (Section 12(a) DPA). Where you have provided freely given, specific, informed, and unambiguous consent to the processing of your data — for example, for the receipt of marketing communications or the processing of sensitive verification data;
• Contractual necessity (Section 12(b) DPA). Where processing is necessary for the performance of the contract between you and jll55 — including account registration, game play, and payment processing;
• Legal obligation (Section 12(c) DPA). Where processing is necessary for jll55 to comply with applicable legal and regulatory obligations — including KYC, AML, and responsible gaming requirements;
• Legitimate interests (Section 12(f) DPA). Where processing is necessary for the legitimate interests of jll55 or a third party — such as fraud prevention, platform security, and service improvement — provided those interests are not overridden by your fundamental rights and freedoms.

6.2 Where jll55 relies on consent as the legal basis for processing, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Requests to withdraw consent should be directed to [email protected].

7.1 jll55 does not sell, rent, or commercially exploit your personal data to third parties. jll55 shares personal data only in the limited circumstances described below:

1. Payment processors. Financial data is shared with GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other payment service providers strictly for the purpose of processing your deposits and withdrawals;
2. Game software providers. Game session data (wager amounts, win/loss outcomes, session timestamps) is shared with third-party game providers solely for game delivery, integrity monitoring, and dispute resolution purposes;
3. Identity verification providers. Verification data, including government-issued ID copies and selfie photographs, may be shared with contracted KYC and identity verification service providers;
4. Regulatory and law enforcement authorities. jll55 will disclose personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council, or other competent Philippine government authorities where required by law, court order, or regulatory instruction;
5. Professional advisors. Personal data may be shared with jll55's legal counsel, auditors, and professional advisors on a need-to-know basis and subject to confidentiality obligations;
6. Business transfers. In the event of a merger, acquisition, or sale of all or substantially all of jll55's assets, personal data may be transferred to the acquiring entity, subject to the continuation of the protections described in this Policy.

7.2 All third-party recipients of jll55 Member data are required to process such data in accordance with the DPA and any applicable data sharing agreement that establishes equivalent safeguards.

8.1 jll55 uses cookies and similar tracking technologies (including session tokens, local storage, and web beacons) to operate and improve the Platform. Cookies are small data files placed on your device that help jll55 recognize your browser, maintain your login session, remember your preferences, and analyze Platform usage.

8.2 The following categories of cookies are used on the jll55 Platform:

• Strictly Necessary Cookies. Required for the Platform to function. These include session authentication cookies, security tokens, and load balancing cookies. These cookies cannot be disabled without impairing Platform functionality.
• Functional Cookies. Used to remember your preferences — such as language and display settings — between sessions to enhance your experience on return visits.
• Analytics Cookies. Used to collect anonymized data about how Members and visitors use the Platform — pages visited, session duration, navigation paths — for the purpose of improving Platform performance and user experience.

8.3 Most browsers allow you to control or disable cookies through browser settings. Disabling strictly necessary cookies will affect your ability to use the Platform, including maintaining login sessions. Disabling analytics cookies will not impair Platform functionality.

8.4 jll55 does not use third-party advertising cookies or tracking pixels for the purpose of serving targeted advertising on external platforms.

9.1 jll55 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. Retention periods applied by jll55 are as follows:

• Account and Identity Data: Retained for the duration of the account relationship plus a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping obligations under Philippine law;
• Financial and Transaction Data: Retained for a minimum of five (5) years following each transaction, in accordance with applicable AML and financial recordkeeping requirements;
• Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the transaction for which they were collected;
• Support and Communications Data: Retained for a period of two (2) years following resolution of the relevant inquiry or complaint;
• Technical and Usage Data: Retained in anonymized or aggregated form for analytical purposes; individually identifiable technical data is retained for up to twelve (12) months;
• Marketing Preferences: Retained until you withdraw consent or update your communication preferences.

9.2 At the expiry of the applicable retention period, jll55 will securely delete or anonymize your personal data unless a longer retention period is required by law. Data subject to an active regulatory inquiry or legal dispute may be retained until the conclusion of that matter.

10.1 jll55 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your browser and jll55 servers — applied to every page of the Platform, not only the login screen;
• Encryption at rest for sensitive personal data stored in jll55 databases, including payment information and verification documents;
• Access controls — personal data is accessible only to jll55 personnel and contracted service providers on a strict need-to-know basis, with role-based access management enforced;
• Anomalous activity monitoring — automated systems monitor for unusual login patterns, suspicious transaction activity, and potential security incidents;
• Regular security reviews and vulnerability assessments of the Platform and its infrastructure.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jll55 will notify the National Privacy Commission and affected data subjects in accordance with the requirements of the DPA and its IRR.

11.1 The jll55 Platform is not directed at, and is not intended for use by, individuals below the age of 21 years. jll55 enforces a strict minimum age requirement of 21 years in accordance with PAGCOR regulations applicable to online gaming in the Republic of the Philippines.

11.2 jll55 conducts age verification as part of the account registration process and again at the point of first withdrawal. Where jll55 discovers or reasonably suspects that personal data has been collected from an individual below the age of 21, jll55 will:

• Immediately suspend the associated Account;
• Delete or anonymize the personal data of the underage individual as promptly as practicable;
• Return any funds deposited by the underage individual to the payment method used, after completion of any required investigation.

11.3 If you are a parent or guardian and believe your child has registered an Account on jll55, please contact [email protected] immediately. jll55 takes all such reports seriously and will act on them promptly.

12.1 As a data subject under the DPA, you have the following rights with respect to your personal data processed by jll55. You may exercise any of these rights by submitting a written request to [email protected]:

12.2 jll55 may request proof of your identity before processing a data subject rights request to ensure that personal data is not disclosed to an unauthorized party. Identity verification for rights requests does not require the submission of additional sensitive data beyond what jll55 already holds.

13.1 The jll55 Platform integrates game software and payment processing services provided by vendors whose infrastructure may be located outside the Republic of the Philippines. In such cases, personal data may be transferred to and processed in jurisdictions outside the Philippines.

13.2 Where personal data is transferred outside the Philippines, jll55 takes appropriate steps to ensure that such transfers are made in accordance with the DPA, including by:

• Entering into data sharing agreements with receiving parties that impose data protection obligations equivalent to those required under Philippine law;
• Transferring data only to jurisdictions that the National Privacy Commission has determined provide an adequate level of data protection; or
• Obtaining your explicit consent to the transfer in cases where other safeguards are not available.

13.3 By registering an Account and using the jll55 Platform, you acknowledge that your personal data may be transferred, stored, and processed outside the Philippines in the circumstances described above.

14.1 The jll55 Platform does not contain links to external third-party websites as a matter of standard policy. In the event that the Platform ever links to an external site, jll55 has no control over and accepts no responsibility for the privacy practices, content, or data protection standards of that site.

14.2 This Policy applies solely to personal data collected and processed by jll55 in connection with the Platform. It does not apply to data collected by third-party software providers' own platforms or services accessed independently of jll55.

15.1 jll55 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. The current version of this Policy is always accessible at jll55.org/privacy-policy.

15.2 Material changes to this Policy — such as changes to the purposes of processing, the categories of data shared with third parties, or your data subject rights — will be communicated to registered Members by notice on the Platform homepage and, where practicable, by email to the registered address on file.

15.3 The effective date displayed at the top of this Policy indicates when the current version came into force. Continued use of the Platform following the effective date of a revised Policy constitutes your acceptance of the updated terms.

16.1 For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jll55, please contact our Data Protection Officer through any of the following channels:

• Email: [email protected] — include "Data Privacy Request" in the subject line for priority routing to the DPO;
• In-Platform Live Chat: Available 24/7 from within your logged-in Account. Our support team will route data privacy inquiries to the DPO promptly.

16.2 If your concern is not resolved to your satisfaction by jll55's DPO within a reasonable timeframe, you may escalate your complaint to the National Privacy Commission of the Philippines in accordance with your rights under the DPA.

16.3 jll55 is committed to resolving all data privacy inquiries and complaints in good faith, promptly, and in full compliance with the DPA and its IRR.