123jl Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by 123jl ("the Company", "we", "us", "our"), the operator of the online casino and sports betting platform accessible at https://123jl.co (the "Platform"). This Policy describes how 123jl collects, processes, stores, discloses, and protects personal data provided by or collected from registered players and visitors to the Platform ("you", "your", "Data Subject").

123jl is committed to protecting the privacy of all individuals who interact with the Platform. We process personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines and circulars issued by the National Privacy Commission (NPC) of the Philippines.

By registering an account or using the 123jl Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree to this Policy, you must not register an account or use the Platform.

2. Personal Data We Collect

123jl collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is processed. The categories of personal data we collect include:

2.1 Sensitive Personal Information

In certain circumstances, 123jl may process sensitive personal information as defined under RA 10173, including government identification numbers and financial account information. Such sensitive data is processed only to the extent strictly necessary to fulfil our legal and regulatory obligations as a PAGCOR-regulated operator, and is subject to enhanced security controls.

3. How We Collect Your Data

123jl collects personal data through the following channels and mechanisms:

• Direct Submission: Data you provide directly when registering a 123jl account, completing identity verification, submitting withdrawal requests, contacting customer support, or participating in promotions.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies (see Section 9 on Cookies).
• Payment Providers: Transaction confirmation data received from payment processors including GCash, Maya, and Philippine bank partners, in connection with deposit and withdrawal processing.
• Identity Verification Services: Where third-party identity verification services are used to process government-issued ID documents submitted during KYC procedures.
• Third-Party Game Providers: Game session data received from 123jl's licensed game software providers in connection with your gameplay activity on the Platform.
• Regulatory Sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with compliance obligations, including self-exclusion register data.

4. How We Use Your Personal Data

123jl uses the personal data collected for the following specific purposes:

• Account Management: To create, maintain, verify, and administer your 123jl player account, including processing your registration and verifying your age (minimum 21 years as required by PAGCOR).
• Service Delivery: To provide access to casino games, the sportsbook, bingo, slots, and all other features of the 123jl Platform.
• Payment Processing: To process deposits via GCash, Maya, QR Ph, and Philippine bank channels, and to execute withdrawal requests to your verified payment method.
• Regulatory Compliance: To fulfil our obligations under PAGCOR's regulatory framework, Philippine anti-money laundering laws (RA 9160 as amended), and the Data Privacy Act.
• Identity Verification (KYC): To verify the identity, age, and eligibility of players as required by PAGCOR and Philippine gaming regulations.
• Responsible Gaming: To monitor gaming behaviour, apply responsible gaming tools requested by players (deposit limits, self-exclusion), and identify players who may be at risk of gambling-related harm.
• Security & Fraud Prevention: To detect, investigate, and prevent unauthorised access, fraud, money laundering, and other prohibited activities on the Platform.
• Customer Support: To respond to enquiries, resolve disputes, and provide technical and account assistance.
• Communications: To send transactional communications including account notifications, OTP codes, withdrawal confirmations, and responsible gaming alerts.
• Platform Improvement: To analyse usage patterns and technical performance data to improve the 123jl Platform experience for Filipino players.
• Promotions: To administer bonuses and promotions you have opted into, and to send promotional communications where you have provided consent to receive them.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, 123jl processes your personal data on the following lawful bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms and Conditions governing your 123jl account, including account creation, game access, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act.
• Legitimate Interests: Processing conducted to pursue 123jl's legitimate business interests in fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for which you have given explicit, freely given, specific, informed, and unambiguous consent, including the sending of promotional marketing communications and certain non-essential cookie use.

6. Data Sharing & Disclosure

123jl does not sell, rent, or trade your personal data to third parties. We may share your personal data only in the following limited circumstances:

6.1 Service Providers

We engage trusted third-party service providers who process personal data on our behalf under binding data processing agreements. These include payment processors (GCash, Maya, BPI, BDO, Metrobank), identity verification service providers, game software providers, fraud detection services, and cloud infrastructure providers. All service providers are contractually bound to process your data solely in accordance with 123jl's instructions and to implement appropriate security measures.

6.2 Regulatory & Legal Disclosure

123jl may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, Philippine law enforcement agencies, or other competent authorities where required by applicable law, regulatory obligation, court order, or legal process.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 123jl's business, personal data may be transferred to the successor entity, subject to equivalent privacy protections. Players will be notified of any such transfer.

7. Data Retention

123jl retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, and compliance obligations. The following retention principles apply:

• Active Accounts: Personal data associated with an active 123jl account is retained for the duration of the account relationship.
• Closed Accounts: Following account closure, 123jl retains transaction records, KYC documentation, and gaming history for a minimum of five (5) years, as required under Philippine anti-money laundering regulations and PAGCOR guidelines.
• Self-Excluded Players: Records of self-excluded players are retained to prevent re-registration during the exclusion period and to fulfil responsible gaming obligations.
• Marketing Data: Where you have provided consent for marketing communications, your contact data used for that purpose is retained until you withdraw consent.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

8. Data Security

123jl implements and maintains comprehensive technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted to and from the Platform
• Encrypted storage of sensitive personal data and financial information
• Access controls limiting personal data access to authorised personnel only, on a need-to-know basis
• SMS OTP two-factor authentication for account login and withdrawal authorisation
• Continuous monitoring systems for suspicious account activity and potential data breaches
• Regular security assessments and penetration testing of the Platform
• Employee training on data privacy and security obligations

Notwithstanding these measures, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, 123jl will notify the National Privacy Commission and affected players in accordance with the breach notification requirements of RA 10173.

9. Cookies & Tracking Technologies

The 123jl Platform uses cookies and similar tracking technologies to enhance your experience, ensure platform security, and analyse usage patterns. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the operation of the Platform, including session authentication, security functions, and maintaining your logged-in state. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and game lobby configuration to provide a personalised experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players navigate and use the Platform, enabling 123jl to improve its services.
• Responsible Gaming Cookies: Store session timing data to support session limit tools and responsible gaming features you have activated.

You can manage your cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from accessing core 123jl services, though some personalisation features may be unavailable.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 123jl:

• Right to be Informed: The right to be informed of how your personal data is being processed, as set out in this Privacy Policy.
• Right of Access: The right to obtain confirmation of whether 123jl holds personal data about you, and to request a copy of that data.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by 123jl.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to 123jl's legal retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller, where technically feasible.
• Right to Object: The right to object to the processing of your personal data on grounds of legitimate interest, including profiling for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact 123jl's Data Protection Officer at [email protected]. We will respond to all data subject requests within fifteen (15) business days, subject to identity verification requirements.

11. Minors & Age Restriction

The 123jl Platform is strictly intended for persons aged 21 years and above in accordance with PAGCOR regulatory requirements. 123jl does not knowingly collect or process personal data from individuals under 21 years of age. Age verification is conducted during the account registration process and may be supplemented by government ID checks.

If 123jl becomes aware that personal data has been collected from an individual under 21 years of age, the account will be immediately closed, deposits returned, and all associated personal data deleted in accordance with applicable law.

12. Cross-Border Data Transfers

In operating the 123jl Platform, personal data may be transferred to or accessed by service providers located outside the Philippines, including game software providers and cloud infrastructure partners based in other jurisdictions. Any such cross-border transfer of personal data is conducted in compliance with the requirements of RA 10173, including where applicable the use of contractual data transfer mechanisms approved by the National Privacy Commission to ensure that transferred data receives an equivalent level of protection as it would under Philippine law.

13. Updates to This Privacy Policy

123jl reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or the 123jl Platform. Material changes to this Policy will be notified to registered players via the mobile number or email address on file, or by a prominent notice on the Platform, prior to the changes taking effect. The "Last Updated" date at the top of this page indicates when the most recent version of this Policy was published. Continued use of the Platform following notification of changes constitutes acceptance of the revised Policy.

14. Contact & Data Protection Officer

For all privacy-related enquiries, data subject rights requests, or complaints, please contact 123jl's designated Data Protection Officer through the following channels:

• Email (DPO): [email protected] — please include "Data Privacy Request" in the subject line
• Live Chat: Available 24/7 within your 123jl account dashboard

If you are not satisfied with 123jl's response to your privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC), the independent supervisory authority responsible for overseeing compliance with RA 10173.