Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how jll4 ("jll4," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("Player," "User," or "you") who access or use the jll4 online gaming platform at jll4.net and any associated mobile applications (collectively, the "Platform").

jll4 is committed to protecting the privacy and personal data of all Filipino players in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as applicable PAGCOR data governance requirements.

By registering an account on jll4 or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you should discontinue use of the Platform and close your jll4 account.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, jll4 acts as the personal information controller in respect of all personal data collected through the Platform. This means jll4 determines the purposes and means by which your personal data is processed.

Where jll4 engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and cloud infrastructure providers — those parties act as personal information processors and are contractually bound to process your data only in accordance with jll4's instructions and this Policy.

3 Personal Data We Collect

jll4 collects personal data in the following categories, depending on how you interact with the Platform:

jll4 does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by law or where you voluntarily provide such information in the context of a responsible gaming self-exclusion request.

4 How We Use Your Personal Data

jll4 uses the personal data we collect for the following purposes:

• Account Management: To create, verify, maintain, and administer your jll4 player account, including identity and age verification to confirm you meet the 21+ eligibility requirement.
• Service Delivery: To provide access to games, process deposits and withdrawals in Philippine Peso (PHP), credit bonuses, and deliver all features of the jll4 Platform.
• Regulatory Compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR reporting requirements, and tax reporting duties.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, collusion, and other prohibited conduct on the jll4 Platform.
• Customer Support: To respond to your queries, complaints, and support requests in a timely and effective manner.
• Responsible Gaming: To monitor gaming behaviour for indicators of problem gambling and to administer self-exclusion, deposit limit, and cooling-off requests in accordance with our Responsible Gaming Policy.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent or where we have a legitimate interest in doing so. You may opt out at any time.
• Platform Improvement: To analyse usage patterns, conduct performance testing, and improve the features, security, and user experience of the jll4 Platform.

5 Legal Basis for Processing

jll4 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and jll4 — specifically, to operate your account and deliver the gaming services you have registered for.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, PAGCOR licensing conditions, and tax obligations.
• Legitimate Interests: Processing is necessary for jll4's legitimate interests in preventing fraud, ensuring Platform security, and improving our services, provided those interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and any processing not covered by the above bases, jll4 relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing and Disclosure

jll4 does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary and for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers require certain financial and identity data to process your deposits and withdrawals securely.
• Identity Verification Providers: Third-party KYC (Know Your Customer) service providers assist jll4 in verifying your identity and age as required by Philippine regulations.
• Cloud and IT Infrastructure Providers: jll4 uses reputable cloud hosting and infrastructure providers to store and process Platform data. These providers are contractually bound to maintain appropriate security standards.
• Regulatory and Law Enforcement Authorities: jll4 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine authorities where required by law, court order, or regulatory directive.
• Professional Advisers: Legal counsel, auditors, and compliance consultants may access personal data on a strictly need-to-know basis and are bound by professional confidentiality obligations.

7 Data Retention

jll4 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your active jll4 account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, or longer if the matter relates to an unresolved dispute or regulatory investigation.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, to demonstrate compliance.
• Technical and Usage Logs: Retained for up to twelve (12) months for security and performance monitoring purposes, after which they are anonymised or deleted.

Upon expiry of the applicable retention period, jll4 will securely delete or anonymise your personal data in accordance with our internal data disposal procedures.

8 Cookies and Tracking Technologies

The jll4 Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and analyse Platform performance. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in to your jll4 account and security cookies that help detect fraudulent activity. These cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, so you do not need to re-enter them on each visit.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the jll4 Platform, helping us identify areas for improvement. No personally identifiable information is included in analytics reports.

jll4 does not use third-party advertising or behavioural tracking cookies. You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may impair the functionality of the jll4 Platform.

9 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jll4. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13.

• Right to be Informed: You have the right to be informed about how jll4 collects and uses your personal data, as set out in this Policy.
• Right of Access: You may request a copy of the personal data jll4 holds about you, along with information about how it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held by jll4. You can update basic account information directly through your jll4 account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jll4's legal retention obligations.
• Right to Data Portability: You may request that jll4 provide your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to jll4's overriding legal obligations.
• Right to Lodge a Complaint: If you believe jll4 has not handled your personal data in accordance with the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

10 Data Security

jll4 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the jll4 Platform.
• Encryption of sensitive data at rest, including financial information and government ID data.
• Role-based access controls ensuring that jll4 staff can only access personal data necessary for their specific job function.
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure.
• Incident response procedures to detect, contain, and notify affected players and the National Privacy Commission in the event of a personal data breach, within the timeframes required by Philippine law.

While jll4 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your jll4 account credentials and for notifying us immediately if you suspect unauthorised access to your account.

11 Children and Minors

The jll4 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law governing online casino-style gaming. jll4 does not knowingly collect personal data from individuals under the age of 21.

If jll4 becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on jll4, please contact our support team immediately so we can investigate and take appropriate action.

12 Changes to This Privacy Policy

jll4 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or regulatory requirements. Where changes are material, jll4 will notify registered players by email or via a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the jll4 Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how jll4 protects your data.

13 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way jll4 handles your personal data, please contact our Data Protection Officer. We are available 24 hours a day, 7 days a week.

Email: support@jll4.net

Please include your registered jll4 account username and a clear description of your request. For data rights requests, we may need to verify your identity before processing your request to protect the security of your account.

You also have the right to raise a concern directly with the National Privacy Commission of the Philippines (NPC) if you believe your data rights have not been respected. Details of how to contact the NPC are available on the NPC's official government website.