Privacy Policy — 81jl Casino

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, the data controller responsible for your personal information is 81jl Casino, operating the platform accessible at https://81jl.app (the "Platform").

As data controller, 81jl Casino determines the purposes and means of processing your personal data. We are committed to processing your data lawfully, fairly, and transparently, and to implementing appropriate technical and organisational measures to protect it against unauthorised access, loss, or misuse.

If you have any questions about how 81jl handles your personal data, or if you wish to exercise any of your rights under the Data Privacy Act, please contact our Data Protection Officer (DPO) using the contact details provided in Section 13 of this Policy.

81jl Casino collects the following categories of personal data from registered players and Platform visitors:

We do not collect sensitive personal information (as defined under the Data Privacy Act) such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where strictly required for identity verification purposes and with your explicit consent.

81jl Casino collects personal data through the following means:

• Direct Interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or updating your account profile;
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs (see Section 8 for details on cookies);
• Third-Party Sources: Identity verification data from KYC service providers; payment confirmation data from GCash, Maya, and Philippine banking partners; fraud detection signals from security service providers;
• Regulatory Sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with our compliance obligations.

81jl Casino processes your personal data only for specific, legitimate purposes. The table below sets out the primary purposes for which we process your data and the legal basis for each under the Data Privacy Act of 2012:

Where we rely on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw that consent at any time by updating your communication preferences in your account settings or by contacting our support team.

81jl Casino does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Processors: GCash, Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, etc.) for the purpose of processing deposits and withdrawals in Philippine Peso;
• KYC & Identity Verification Providers: Third-party services that assist in verifying your identity and age in compliance with PAGCOR and AML requirements;
• Fraud Prevention & Security Services: Providers that help us detect and prevent fraudulent activity, money laundering, and account takeover attempts;
• IT Infrastructure Providers: Cloud hosting and data centre providers that store Platform data on our behalf, subject to strict data processing agreements;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or court order;
• Professional Advisers: Lawyers, auditors, and accountants where necessary for legal compliance or dispute resolution.

81jl Casino retains your personal data only for as long as 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 Data: Retained for the duration of your active account, plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act and BSP regulations;
• KYC & Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction;
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session, for dispute resolution and regulatory audit purposes;
• Support Communications: Retained for two (2) years from the date of the last communication, unless the matter relates to an ongoing dispute;
• Technical & Usage Data: Retained for up to twelve (12) months from collection, after which it is aggregated or anonymised.

When personal data is no longer required, 81jl Casino will securely delete or anonymise it in accordance with our internal data disposal procedures. Anonymised data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

81jl Casino implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and the 81jl platform is encrypted using industry-standard Transport Layer Security (TLS) protocols;
• Data Encryption at Rest: Sensitive personal and financial data stored on our servers is encrypted using AES-256 encryption;
• Access Controls: Access to personal data is restricted to authorised personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication;
• Firewalls & Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls and continuous intrusion detection and prevention systems;
• Regular Security Audits: We conduct periodic penetration testing and security audits of our platform and infrastructure;
• Staff Training: All 81jl personnel who handle personal data receive regular data privacy and security training;
• Incident Response: We maintain a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights, we will notify the National Privacy Commission (NPC) within 72 hours and affected individuals without undue delay, as required by the Data Privacy Act.

The 81jl Casino platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and gather analytics data that helps us improve the Platform. A cookie is a small text file placed on your device when you visit a website.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled;
• Functional Cookies: Remember your preferences such as language settings, responsible gaming limits you have set, and your preferred game lobby view. Disabling these may affect Platform functionality;
• Analytics Cookies: Help us understand how players use the Platform — which games are most popular, how long sessions last, and where users encounter difficulties. This data is aggregated and does not identify you personally;
• Security & Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, bot access, and account takeover attempts.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the 81jl platform, including your ability to stay logged in or access certain game features. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

As a data subject under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by 81jl Casino:

• Right to Be Informed: You have the right to be informed of how your personal data is being collected and processed — which is the primary purpose of this Privacy Policy;
• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is being processed;
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You can update most account information directly in your account settings;
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations under PAGCOR and AML regulations;
• Right to Object: You have the right to 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 our overriding legal obligations;
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format where technically feasible;
• Right to Lodge a Complaint: If you believe your data privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13. We will respond to all verified requests within fifteen (15) business days. We may need to verify your identity before processing your request to protect against unauthorised access to your data.

Age verification is conducted as part of the account registration and KYC process. If 81jl Casino discovers that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the collected data, and return any deposited funds in accordance with applicable regulations.

If you are a parent or guardian and believe that a minor in your care has registered on the 81jl platform, please contact our support team immediately at the contact details provided in Section 13. We take underage gambling extremely seriously and will act promptly on all such reports.

In the course of operating the 81jl Casino platform, your personal data may be transferred to and processed in countries outside the Philippines — for example, where our cloud infrastructure providers or KYC service providers are located.

Where such transfers occur, 81jl Casino ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include:

• Contractual clauses in data processing agreements that require recipient parties to protect your data to Philippine standards;
• Transfers only to countries or organisations that the National Privacy Commission has determined provide an adequate level of data protection;
• Implementation of additional technical security measures where transfers occur to jurisdictions with lower baseline protections.

By using the 81jl platform and accepting this Privacy Policy, you acknowledge and consent to the transfer of your personal data as described in this section, subject to the safeguards outlined above.

81jl Casino reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. When material changes are made, we will notify registered players via email to their registered address and/or via a prominent notice on the Platform.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how 81jl protects your personal data. Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acceptance of the changes.

If you do not agree with any changes to this Privacy Policy, you should cease using the Platform and may request account closure in accordance with the Terms & Conditions. For the full Terms governing your use of 81jl, please visit our Terms & Conditions page.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 81jl Casino, please contact our Data Protection Officer (DPO). Our DPO is responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy.

We aim to respond to all data privacy requests and complaints within fifteen (15) business days. For complex requests, we may require up to thirty (30) days and will notify you of the extended timeline.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.