jlbe Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how jlbe ("we," "us," or "our"), the operator of the online gaming platform accessible at jlbe.app, collects, uses, stores, shares, and protects the personal information of users ("you" or "your") who access or use the jlbe platform and its associated services.

jlbe operates as a Personal Information Controller as defined under Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"). We are registered with and subject to the oversight of the National Privacy Commission (NPC) of the Philippines.

By registering for a jlbe account, accessing the jlbe platform, or using any jlbe service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the jlbe platform.

This Policy should be read together with the jlbe Terms & Conditions and any other policies or notices published on the jlbe platform that may apply to specific services or features.

Personal Data We Collect

jlbe collects the following categories of personal data from users:

Identity & Contact Information:

• Full legal name
• Date of birth
• Gender
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license)

Financial Information:

• GCash or Maya account details (mobile number associated with the account)
• Bank account details (for bank transfer transactions)
• Debit card details (card number, expiry — processed securely and not stored in full)
• Transaction history, including deposits, withdrawals, and wagers

Technical & Usage Data:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Login timestamps and session duration
• Pages visited, games played, and features used on the jlbe platform
• Cookies and similar tracking technologies (see Section 7)

Communications Data:

• Records of communications with jlbe support, including chat logs and email correspondence
• Feedback, complaints, and survey responses submitted to jlbe
• Promotional preferences and marketing consent records

How We Collect Your Data

jlbe collects personal data through the following means:

• Direct submission: Information you provide when registering for a jlbe account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and interact with the jlbe platform, including through cookies, web beacons, and server logs.
• Third-party sources: Information received from payment processors (such as GCash and Maya), identity verification service providers, fraud prevention agencies, and regulatory bodies, where permitted by law.
• KYC verification: Documents and information submitted as part of the Know Your Customer process, including copies of government-issued identification and proof of address.

jlbe does not collect personal data from third-party social media platforms or data brokers. All data collected by jlbe is obtained through the channels described above.

How We Use Your Personal Data

jlbe uses the personal data it collects for the following purposes:

• Account management: To create, maintain, verify, and manage your jlbe account, including processing your registration and authenticating your identity at login.
• Service delivery: To provide you with access to jlbe's games, promotions, and platform features, and to process your deposits, withdrawals, and wagers.
• KYC and regulatory compliance: To verify your identity and age (21+), comply with anti-money laundering (AML) obligations, and meet reporting requirements under applicable Philippine law and gaming regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct on the jlbe platform.
• Customer support: To respond to your inquiries, resolve complaints, and provide technical assistance.
• Responsible gaming: To monitor gaming behavior, identify signs of problem gambling, and administer responsible gaming tools such as deposit limits and self-exclusion.
• Marketing and promotions: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may opt out at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the jlbe platform's features, performance, and user experience.
• Legal obligations: To comply with applicable laws, regulations, court orders, and lawful requests from government authorities, including PAGCOR and the NPC.

jlbe will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

Legal Basis for Processing

jlbe processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its IRR:

• Consent: Where you have given your express consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary for the performance of the contract between you and jlbe — specifically, the Terms & Conditions governing your use of the platform.
• Legal obligation: Where processing is required to comply with a legal obligation applicable to jlbe, including AML regulations, gaming licensing requirements, and tax reporting obligations.
• Legitimate interests: Where processing is necessary for the legitimate interests of jlbe, such as fraud prevention, platform security, and responsible gaming monitoring, provided that such interests are not overridden by your rights and freedoms.

Sharing Your Personal Data

jlbe does not sell, rent, or trade your personal data to any third party. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, Maya, and Philippine banking partners, for the purpose of processing your deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and comply with regulatory requirements.
• IT and platform service providers: Cloud hosting, data storage, cybersecurity, and analytics providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other government bodies, where disclosure is required by law or regulatory directive.
• Legal and professional advisors: Lawyers, auditors, and compliance consultants engaged by jlbe, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of jlbe's business or assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom jlbe shares personal data are required to handle such data in accordance with applicable Philippine privacy laws and jlbe's data protection standards.

Cookies & Tracking Technologies

jlbe uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and support security and fraud prevention measures. The following types of cookies are used:

• Essential cookies: Strictly necessary for the operation of the jlbe platform, including session management, authentication, and security. These cannot be disabled without affecting platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data about how users interact with the jlbe platform, helping us identify areas for improvement.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jlbe platform. jlbe does not use cookies to serve third-party advertising or to track your activity on other websites.

Data Security

jlbe implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your device and the jlbe platform is encrypted using industry-standard SSL/TLS protocols.
• Encryption at rest: Sensitive personal data stored on jlbe's servers is encrypted using strong encryption algorithms.
• Access controls: Access to personal data is restricted to authorized jlbe personnel and service providers on a strict need-to-know basis. All access is logged and monitored.
• Regular security audits: jlbe conducts periodic security assessments, vulnerability scans, and penetration tests to identify and address potential security weaknesses.
• Incident response: jlbe maintains a documented data breach response plan. In the event of a breach affecting your personal data, jlbe will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, as required by the DPA.
• Staff training: All jlbe personnel with access to personal data receive regular training on data protection obligations and security best practices.

While jlbe takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the security of your jlbe account credentials and for notifying us immediately of any suspected unauthorized access.

Data Retention

jlbe retains your personal data for as long as is necessary to fulfill 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 account's active status and for a period of at least five (5) years following account closure, in compliance with AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and related regulations.
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by law.
• Support communications: Retained for a period of two (2) years from the date of the last communication, unless a longer retention period is required for legal or compliance purposes.
• Marketing consent records: Retained for the duration of your consent and for a reasonable period thereafter as evidence of consent.

Upon expiry of the applicable retention period, jlbe will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless retention is required by a specific legal obligation.

Your Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jlbe:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data jlbe holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data jlbe holds about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jlbe's legal retention obligations.
• 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 data portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact jlbe's Data Protection Officer using the contact details provided in Section 15 of this Policy. jlbe will respond to all valid requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

Children's Privacy

The jlbe platform is strictly intended for individuals who are 21 years of age or older. jlbe does not knowingly collect, process, or store personal data from individuals under the age of 21.

If jlbe becomes aware that personal data has been collected from a person under 21 years of age, it will immediately suspend the relevant account, delete the associated personal data, and take appropriate action in accordance with applicable law.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to jlbe, please contact us immediately using the details in Section 15 so that we can take prompt corrective action.

International Data Transfers

jlbe primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international fraud prevention services.

Where such transfers occur, jlbe ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law.
• Transfers only to countries or organizations that have been assessed as providing an adequate level of data protection.
• Compliance with NPC guidelines on cross-border data transfers.

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

Third-Party Links

The jlbe platform may contain links to third-party websites or services for informational or operational purposes. jlbe is not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies solely to the jlbe platform and its associated services.

We encourage you to review the privacy policies of any third-party websites you visit. jlbe does not endorse or make any representations about third-party websites or their data handling practices.

Updates to This Privacy Policy

jlbe reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, jlbe will notify registered users via email or a prominent notice on the platform prior to the changes taking effect.

The date of the most recent revision is always displayed at the top of this page. Your continued use of the jlbe platform after the effective date of any revised Privacy Policy constitutes your acknowledgment of and agreement to the updated terms.

If you do not agree with any changes to this Privacy Policy, you must stop using the jlbe platform and may request account closure in accordance with the jlbe Terms & Conditions.

Contact & Data Protection Officer

jlbe has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact our DPO using the details below.

All contact details are provided as plain text only and are not clickable links:

If you are not satisfied with jlbe's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.

For responsible gaming concerns, including self-exclusion and account restrictions, please visit our Responsible Gaming page.