Privacy Policy

1. Introduction

1.1 jlsot is committed to protecting the privacy and personal data of all individuals who interact with the Platform. This Policy sets out, in plain and legally clear terms, exactly what data jlsot collects, why it is collected, how it is used, and the rights available to you as a data subject.

1.2 This Policy applies to all personal data collected through jlsot.cam, including data collected during account registration, KYC verification, deposits, withdrawals, gameplay, customer support interactions, and marketing communications.

1.3 This Policy should be read together with jlsot's Terms & Conditions and Responsible Gaming Policy, all of which form part of the agreement between you and jlsot. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

1.4 jlsot operates primarily in the Philippines and is committed to compliance with the Republic Act No. 10173 — the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines.

2. Data Controller

2.1 For the purposes of this Policy and applicable data protection law, jlsot acts as the data controller in respect of all personal data collected through the Platform. As data controller, jlsot determines the purposes and means of processing your personal data.

2.2 Where jlsot engages third-party service providers to process personal data on its behalf (for example, payment processors, KYC verification providers, and analytics platforms), such providers act as data processors under jlsot's instructions and are bound by data processing agreements that impose obligations consistent with this Policy.

2.3 Contact details for data protection inquiries are set out in Section 15 of this Policy.

3. Personal Data We Collect

3.1 jlsot collects personal data from you directly (when you provide it) and automatically (when you use the Platform). The categories of personal data collected include:

3.2 jlsot does not intentionally collect sensitive personal information beyond what is required for identity verification and responsible gaming compliance (such as confirmation of age). Where sensitive information is collected, it is processed under the applicable lawful bases described in Section 5.

3.3 You are not legally obligated to provide your personal data to jlsot. However, failure to provide mandatory information (such as identity and age verification data) will prevent you from opening or maintaining a jlsot account, as such data is required by law and regulatory obligation.

4. How We Use Your Personal Data

4.1 jlsot uses the personal data it collects for the following purposes:

• Account Registration and Management: To create, maintain, and administer your jlsot account, including verifying your identity and ensuring the integrity of your account;
• KYC and AML Compliance: To verify your age (minimum 21 years), identity, and source of funds in accordance with PAGCOR licensing requirements and applicable anti-money laundering law;
• Transaction Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods in Philippine Peso;
• Game Delivery and Platform Operation: To provide access to the game lobby, record bet histories, display account balances, and maintain the technical infrastructure of the Platform;
• Responsible Gaming Compliance: To monitor gaming behavior, enforce deposit limits set by players, implement self-exclusion requests, and identify patterns that may indicate problem gambling;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct;
• Customer Support: To respond to inquiries, resolve disputes, process complaints, and maintain records of support interactions;
• Marketing and Promotions: To send promotional communications, bonus notifications, and platform updates to players who have opted in to marketing communications. You may opt out at any time;
• Analytics and Platform Improvement: To analyze usage patterns, identify technical issues, and improve the performance and features of the jlsot Platform;
• Legal and Regulatory Compliance: To comply with applicable law, respond to lawful requests from regulatory authorities, and enforce our Terms & Conditions.

5. Legal Basis for Processing

5.1 Under the Data Privacy Act of 2012 and its Implementing Rules, jlsot processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and jlsot (i.e., the Terms & Conditions) — including account registration, transaction processing, and game delivery;
• Legal Obligation: Processing is required to comply with applicable laws, including PAGCOR licensing conditions, AML regulations, KYC requirements, and tax obligations;
• Legitimate Interests: Processing is necessary for jlsot's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and analytics, provided such interests are not overridden by your rights;
• Consent: Where processing is based on consent (for example, marketing communications), you may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. Data Sharing and Disclosure

6.1 jlsot does not sell, rent, or trade your personal data to third parties for their independent marketing use. Your personal data may be shared in the following limited circumstances:

• Service Providers (Data Processors): Third-party providers engaged by jlsot to deliver services on its behalf, including payment gateway operators, KYC/identity verification providers, IT infrastructure and hosting providers, customer support software providers, and analytics platforms. These providers process data under jlsot's instructions and are bound by contractual data protection obligations;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law, court order, or regulatory directive;
• Law Enforcement: Philippine law enforcement agencies where jlsot has a reasonable belief that disclosure is required to prevent, detect, or investigate criminal activity, including fraud or money laundering;
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of jlsot's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections as set out in this Policy;
• With Your Consent: In any other circumstances where you have given explicit prior consent to the sharing of your personal data.

6.2 jlsot will not disclose your personal data to any third party except as described in this Section or as otherwise required by applicable law.

7. Cookies and Tracking Technologies

7.1 jlsot uses cookies and similar tracking technologies (including web beacons and local storage) to operate and improve the Platform. Cookies are small text files placed on your device when you visit jlsot.cam.

7.2 jlsot uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your jlsot account during a visit. These cannot be disabled without affecting core Platform functionality;
• Performance and Analytics Cookies: Used to collect anonymized information about how visitors use the Platform, such as pages visited and time spent. This data helps jlsot identify areas for improvement;
• Functional Cookies: Used to remember your preferences and settings, such as your preferred language and notification settings, to provide a more personalized experience;
• Security Cookies: Used to detect and prevent fraudulent activity, monitor session integrity, and enforce login security measures.

7.3 You can manage or disable non-essential cookies through your browser settings. Most modern browsers allow you to refuse or delete cookies. However, disabling strictly necessary cookies may impair your ability to use the jlsot Platform, including accessing your account.

7.4 jlsot does not use cookies to track your activity on third-party websites or to serve targeted advertising on external platforms.

8. Data Retention

8.1 jlsot retains your personal data for as long as necessary to fulfil the purposes described in this Policy, and in particular:

• Account Data: Retained for the duration of your active jlsot account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping obligations;
• 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 PAGCOR regulations;
• KYC Documents: Retained for a minimum of five (5) years following account closure or the end of the business relationship;
• Customer Support Records: Retained for a minimum of two (2) years from the date of the most recent interaction;
• Technical and Usage Logs: Typically retained for twelve (12) months, unless a longer retention period is required for fraud investigation or legal proceedings.

8.2 Where personal data is no longer required for any lawful purpose, jlsot will take reasonable steps to securely delete or anonymize that data in accordance with its data retention and destruction procedures.

9. Data Security

9.1 jlsot implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption on all data transmissions between your device and jlsot servers;
• Encryption of stored sensitive data, including identity verification documents and financial records;
• Access controls limiting internal access to personal data to authorized personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Secure password hashing protocols — jlsot does not store plaintext passwords;
• Multi-factor authentication options for account login.

9.2 While jlsot takes all reasonable steps to protect your data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your jlsot account credentials and for notifying jlsot immediately if you suspect unauthorized access to your account.

10. Your Data Protection Rights

10.1 Under the Data Privacy Act of 2012 and applicable Philippine privacy law, you have the following rights in respect of your personal data held by jlsot:

10.2 To exercise any of the rights listed above, please contact jlsot using the details in Section 15. jlsot will respond to all verified data subject requests within thirty (30) calendar days, or such extended period as permitted by applicable law where the request is complex.

10.3 jlsot may be required to verify your identity before processing a data subject request to protect against unauthorized access to another person's data.

11. Children's Privacy

11.1 If jlsot discovers that personal data has been collected from an individual under the age of 21, it will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage user will be refunded to the payment source.

11.2 If you are a parent or guardian and believe that your child has registered on jlsot or provided personal data to jlsot, please contact jlsot support immediately using the details in Section 15.

12. Cross-Border Data Transfers

12.1 jlsot is a Philippine-focused platform. Where personal data is transferred to or processed by service providers located outside the Philippines (for example, hosting infrastructure or analytics platforms), jlsot ensures that appropriate safeguards are in place, including:

• Contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under Philippine law;
• Engagement of service providers in jurisdictions recognized as providing adequate data protection standards;
• Data processing agreements binding all processors to jlsot's privacy requirements and the DPA's standards.

12.2 By using the jlsot Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines in accordance with this Section.

13. Third-Party Links and Services

13.1 The jlsot Platform may contain links to third-party game providers, payment processors, or other services. This Policy applies solely to jlsot.cam and the jlsot Platform. jlsot is not responsible for the privacy practices of any third-party website or service, and you are encouraged to review the privacy policies of any third-party services you interact with.

13.2 Third-party game providers whose games are accessible through jlsot may process certain technical data (such as game session data) directly. Such processing is governed by the relevant provider's own privacy policy and data processing agreements with jlsot.

14. Updates to This Privacy Policy

14.1 jlsot reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. Updated versions will be published on this page with a revised "Last Updated" date at the top of the Policy.

14.2 For material changes to this Policy that may affect your rights or the way jlsot handles your data, jlsot will provide advance notice to registered players via the email address on file or via a prominent notice on the Platform.

14.3 Your continued use of the jlsot Platform following publication of an updated Privacy Policy constitutes your acknowledgment of and agreement to the changes. If you do not agree with any amendment, you must cease using the Platform and may request account closure under Section 11.2 of the Terms & Conditions.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy, or wish to exercise any of your data protection rights described in Section 10, please contact jlsot's data protection team using the following details:

• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through the jlsot Platform

For complaints that cannot be resolved directly with jlsot, you may escalate to the National Privacy Commission of the Philippines. Information about the NPC and how to lodge a complaint is available through official Philippine government channels.