jll22 Privacy Policy
At jll22, protecting your personal information is something we take seriously. This Privacy Policy explains exactly what data we collect, why we collect it, how it is used, who it may be shared with, and what rights you have over your own information as a registered player on the jll22 platform.
How jll22 Protects Your Privacy
These highlights summarise the most important aspects of our data practices. The complete and legally binding Privacy Policy appears in full below.
Data Security
All data transmitted between your device and jll22 is protected by 256-bit SSL encryption. Personal data stored on jll22 servers is held in access-controlled environments with encryption at rest. We conduct regular security assessments and apply patches promptly to maintain the integrity of our data infrastructure.
Your Data Rights
As a jll22 account holder, you have the right to access the personal data we hold about you, request corrections, ask for deletion where legally permissible, withdraw marketing consent at any time, and request a portable copy of your data. These requests can be submitted to our support team and will be addressed within 30 days.
No Data Selling
jll22 does not sell, rent, or trade your personal data to unaffiliated third parties for their own marketing purposes. Data is shared only with service providers who assist in operating the platform, with regulatory bodies as required by law, and with payment processors necessary to complete your transactions.
Payment Data Handling
jll22 does not store full GCash account credentials, Maya PINs, or complete bank account details on our servers. Payment processing is handled by certified payment gateways that operate under their own PCI-DSS compliant security standards. jll22 retains only the transaction records necessary for accounting, compliance, and dispute resolution.
Data Retention
We retain your personal data for as long as your jll22 account is active and for a minimum of five (5) years after account closure, as required by applicable Philippine anti-money laundering regulations and gaming compliance obligations. After the retention period, personal data is securely deleted or anonymised.
Philippine Data Law Compliance
jll22 processes personal data in accordance with the Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations as enforced by the National Privacy Commission (NPC) of the Philippines. Our data practices are aligned with the principles of transparency, legitimate purpose, and proportionality under the DPA.
1 Introduction
This Privacy Policy ("Policy") describes how jll22 ("jll22," "we," "us," "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," "Player") who register for or use the jll22 online casino and sports betting platform accessible at jll22.cam (the "Platform").
jll22 is committed to protecting the privacy of all Players and to handling personal data responsibly, transparently, and in full compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and all other applicable laws and regulations.
By registering an account on the Platform or by continuing to use jll22's services, you acknowledge that you have read and understood this Policy and consent to the collection, use, and disclosure of your personal data as described herein. If you do not agree to this Policy, please do not register for or continue to use the Platform.
This Policy should be read together with jll22's Terms & Conditions, which govern your overall use of the Platform. In the event of any inconsistency, this Policy shall prevail with respect to the processing of personal data.
2 Data Controller
For the purposes of the Data Privacy Act of 2012 and its IRR, jll22 is the Personal Information Controller (PIC) in respect of the personal data collected and processed through the Platform. As PIC, jll22 determines the purpose and means of processing your personal information.
jll22 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection law. The DPO can be contacted through the support email address provided in Section 15 of this Policy. Correspondence directed to the DPO should be clearly marked "For the attention of the Data Protection Officer."
3 Personal Data We Collect
3.1 Data You Provide Directly
When you register, verify your account, contact support, or use other features of the Platform, jll22 may collect the following categories of personal data that you provide directly:
- Identity Data: Full legal name, date of birth, gender, nationality
- Contact Data: Philippine mobile number, email address, residential address
- Verification Data: Government-issued ID type and number (e.g., passport, UMID, PhilSys ID, driver's licence), selfie or photograph submitted for KYC
- Financial Data: GCash mobile number, Maya account details, bank account name and number (for InstaPay withdrawals), cryptocurrency wallet address (where applicable), transaction history
- Account Data: Username, password (stored in hashed form), account preferences, responsible gaming settings
- Communications Data: Messages exchanged with jll22 support staff via live chat, email, or other channels
3.2 Data Collected Automatically
When you access the Platform, jll22's systems automatically collect certain technical data, including:
- IP address and approximate geolocation derived from IP
- Device type, operating system, and browser version
- Session data including login times, session duration, and pages visited
- Game activity logs including bets placed, games played, results, and wager amounts
- Cookies and similar tracking technologies (see Section 7)
- Referral source if you arrived via a promotional or affiliate link
3.3 Data from Third Parties
jll22 may receive personal data about you from third-party sources in limited circumstances, including KYC verification service providers who assist in identity and age verification, payment processors who confirm transaction completion, and fraud detection services that flag irregular account activity patterns.
4 How We Use Your Personal Data
jll22 processes your personal data only for specified, legitimate purposes. The table below summarises the primary purposes for which your data is used and the corresponding legal basis for each:
| Purpose | Data Categories Used | Legal Basis |
|---|---|---|
| Account registration and management | Identity, Contact, Account | Contractual necessity |
| KYC identity and age verification | Identity, Verification | Legal obligation; Regulatory compliance |
| Processing deposits and withdrawals | Financial, Identity | Contractual necessity |
| Preventing fraud and money laundering | All categories as relevant | Legal obligation; Legitimate interest |
| Responsible gaming monitoring | Account, Game activity | Legal obligation; Legitimate interest |
| Customer support | Identity, Contact, Communications | Contractual necessity |
| Platform security and abuse prevention | Technical, Account | Legitimate interest |
| Service improvement and analytics | Technical (anonymised or aggregated) | Legitimate interest |
| Direct marketing (with consent) | Contact, Account preferences | Consent |
| Regulatory reporting to PAGCOR | Identity, Financial, Game activity | Legal obligation |
5 Legal Basis for Processing
jll22 processes your personal data only where a lawful basis under the Data Privacy Act of 2012 exists. The primary legal bases jll22 relies upon are:
- Consent: Where you have provided clear, informed consent, such as opting in to receive marketing communications. You may withdraw consent at any time without detriment to your account.
- Contractual Necessity: Where processing is necessary to perform our obligations under the Terms & Conditions, including operating your account, processing payments, and delivering gaming services.
- Legal Obligation: Where processing is required to comply with Philippine law, including KYC obligations, anti-money laundering reporting, PAGCOR regulatory requirements, and the Data Privacy Act itself.
- Legitimate Interest: Where processing is necessary for jll22's legitimate business interests, including fraud prevention, platform security, and improving user experience, provided that such interests are not overridden by your fundamental rights and interests.
6 Sharing and Disclosure of Personal Data
6.1 Service Providers
jll22 engages third-party service providers who process personal data on our behalf as Personal Information Processors (PIPs) under the DPA. These include KYC verification providers, payment gateway operators, cloud infrastructure and hosting providers, fraud detection and security services, customer support platform providers, and analytics service providers. All PIPs are contractually required to process data only on jll22's documented instructions and to maintain appropriate security standards.
6.2 Regulatory and Law Enforcement Disclosure
jll22 is required by Philippine law and regulatory obligations to disclose certain player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement authorities, where such disclosure is required by applicable law, court order, or valid regulatory directive. jll22 will not notify Players of such disclosures where prohibited by law from doing so.
6.3 Business Transfers
In the event that jll22 undergoes a merger, acquisition, restructuring, or sale of all or a material part of its assets, personal data held by jll22 may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and the identity of the new data controller in advance where practically possible.
6.4 No Sale of Personal Data
jll22 does not sell, rent, or otherwise transfer your personal data to unaffiliated third parties for their own commercial or marketing purposes. Any data sharing is limited to the purposes described in this Policy and is governed by appropriate data processing agreements.
7 Cookies and Tracking Technologies
7.1 What Cookies We Use
The jll22 Platform uses cookies and similar tracking technologies (including local storage and session tokens) to operate the platform, maintain your login session, remember your preferences, detect fraud, and analyse platform usage. The primary categories of cookies used by jll22 are:
- Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens and security cookies. These cannot be disabled without impairing your ability to use the Platform.
- Functional Cookies: Used to remember your preferences such as language settings, responsible gaming configurations, and display preferences across sessions.
- Analytical Cookies: Used in aggregate and anonymised form to understand how Players navigate the Platform and to identify areas for improvement. jll22 does not use these cookies to identify individual Players for marketing profiling.
- Security Cookies: Used to detect and prevent fraudulent activity, including bot detection and repeated failed login attempt tracking.
7.2 Cookie Management
You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform, including your ability to remain logged in between page navigations. Strictly necessary cookies cannot be disabled via browser settings without logging out of your account.
8 Data Security
jll22 implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data we process. These measures include, but are not limited to:
- 256-bit SSL/TLS encryption for all data in transit between your device and jll22 servers
- Encryption of sensitive personal data at rest on jll22 infrastructure
- Role-based access controls limiting staff access to personal data on a need-to-know basis
- Regular penetration testing and security vulnerability assessments
- Two-factor authentication available for all Player accounts
- Automated detection of suspicious login patterns and account activity
- Staff training on data protection obligations and information security practices
Important: No internet transmission is completely secure. While jll22 employs industry-standard security measures, we cannot guarantee absolute security of your data. You remain responsible for maintaining the confidentiality of your own jll22 login credentials. Do not share your password or OTP with anyone.
8.1 Data Breach Response
In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected Players, jll22 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, as required under the DPA and its IRR. Affected Players will be notified without undue delay where the breach is likely to result in a high risk to their rights, using the contact information held on their account.
9 Data Retention
jll22 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, regulatory, or reporting requirements.
Specifically:
- Active Accounts: Personal data is retained for the duration of the account relationship plus a minimum of five (5) years following account closure, as required under the Anti-Money Laundering Act (AMLA) as amended and PAGCOR compliance obligations.
- KYC Documents: Identity and age verification documents are retained for a minimum of five (5) years from the date of submission or account closure, whichever is later.
- Transaction Records: Financial transaction data is retained for a minimum of five (5) years from the date of transaction for audit and regulatory compliance purposes.
- Support Communications: Records of customer support interactions are retained for up to three (3) years from the date of the interaction.
- Marketing Consent Records: Retained for the period of the consent plus three (3) years to demonstrate compliance with consent requirements.
Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised such that it can no longer be linked to an identifiable individual.
10 Your Data Rights
Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by jll22. These rights can be exercised by contacting us through the channels set out in Section 15:
Right to AccessYou have the right to request a copy of the personal data jll22 holds about you, together with information about how it is processed. jll22 will respond to access requests within thirty (30) calendar days.
Right to RectificationYou have the right to request correction of any inaccurate, incomplete, or outdated personal data we hold about you. Some corrections can be made directly within your account settings; others may require supporting documentation.
Right to ErasureYou have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected and no legal obligation requires its retention. Note that jll22 may be unable to delete data required to be retained under applicable law, including AML and regulatory retention obligations.
Right to ObjectYou have the right to object to the processing of your personal data for direct marketing purposes at any time, with effect from receipt of your objection. You also have the right to object to processing based on legitimate interests, subject to compelling legitimate grounds that override your rights.
Right to Data PortabilityWhere technically feasible and where processing is carried out by automated means on the basis of your consent or contractual necessity, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format.
Right to RestrictionYou may request that jll22 restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where processing is unlawful but you prefer restriction to erasure.
Right Against Automated Decision-MakingYou have the right not to be subject to a decision based solely on automated processing, including profiling, where that decision produces a significant legal effect or similarly significant impact on you, without human review being available on request.
11 Marketing Communications
With your consent, jll22 may send you marketing communications about promotions, bonuses, new game releases, and other offers available on the Platform. These communications may be delivered by SMS to your registered Philippine mobile number or by email to your registered email address.
You may withdraw your consent to receive marketing communications at any time by:
- Adjusting your communication preferences in the Notifications section of your jll22 account settings
- Clicking the unsubscribe link included in any marketing email
- Replying "STOP" to any marketing SMS
- Contacting jll22 support directly
Withdrawal of marketing consent does not affect your ability to receive service-related communications such as withdrawal confirmations, security alerts, OTP messages, or support responses, which are sent on the basis of contractual necessity and are not subject to marketing preferences.
12 Protection of Minors
The jll22 Platform is strictly intended for individuals aged 21 and above. jll22 does not knowingly collect or process personal data of individuals under the age of 21. Registration and use of the Platform by persons under 21 is prohibited under both jll22's Terms & Conditions and applicable Philippine gaming law.
If you are under 21: You must not register for or use jll22. If you believe a minor has created a jll22 account, please contact our support team immediately. jll22 will take prompt action to close such accounts and delete any personal data collected from individuals found to be under 21.
13 International Data Transfers
The jll22 Platform primarily serves Philippine players and jll22 endeavours to store and process personal data within the Philippines or in jurisdictions that provide an adequate level of data protection comparable to the DPA. In limited circumstances, personal data may be transferred to and processed by third-party service providers located outside the Philippines, for example where cloud infrastructure or specialist services are hosted internationally.
Where personal data is transferred outside the Philippines, jll22 ensures that appropriate safeguards are in place, including data processing agreements that impose data protection obligations on the recipient consistent with the DPA, or through reliance on adequacy determinations or equivalent legal mechanisms recognised under the DPA and its IRR.
14 Changes to This Privacy Policy
jll22 may update or amend this Privacy Policy from time to time to reflect changes in our data practices, operational developments, or changes in applicable law. Material changes to this Policy will be communicated to registered Players via the email address or mobile number on file at least fourteen (14) days before the changes take effect, except where an urgent amendment is required to comply with a legal obligation, in which case it may take immediate effect with concurrent notification.
The current version of this Policy is always accessible at jll22.cam/privacy-policy. The effective date at the top of this document indicates when the current version came into force. Your continued use of the Platform following the effective date of any revision constitutes your acknowledgment of the updated Policy.
15 Contact Us & How to Raise a Complaint
15.1 Exercising Your Rights
To exercise any of your data rights described in Section 10, to raise a data protection concern, or to contact our Data Protection Officer, please use the following contact details:
Data Protection Officer / Customer Privacy Team
Email: [email protected]
Please include "Data Privacy Request" in your subject line. We will acknowledge your request within five (5) business days and aim to provide a full response within thirty (30) calendar days. Where requests are complex or numerous, we may extend this period by a further thirty (30) days with prior notice.
15.2 Complaints to the National Privacy Commission
If you are not satisfied with jll22's response to your data privacy concern, or if you believe that jll22 has violated your rights under the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory authority responsible for administering and implementing the DPA. Information on how to file a complaint with the NPC is publicly available through NPC's official channels.
Questions About Your jll22 Data?
Our support team is available 24/7 in Tagalog and English. Whether you want to access your data, update your marketing preferences, or ask a question about this Policy, we are here to help.
Must be 21 or older to register and play. Play responsibly.