jlttt Privacy Policy

This Privacy Policy ("Policy") is issued by jlttt ("jlttt," "we," "us," or "our") and applies to all personal data collected through the jlttt website, mobile platform, and all associated services (collectively, the "Platform"). jlttt is committed to protecting the privacy and personal data of all users ("you," "Player," or "User") in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

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

This Policy should be read together with the jlttt Terms & Conditions, which govern your overall use of the Platform.

jlttt collects the following categories of personal data from players:

Identity & Contact Data:

• Full legal name as it appears on your government-issued ID.
• Date of birth (for age verification — 21+ requirement under PAGCOR regulations).
• Philippine mobile number and email address.
• Residential address in the Philippines.
• Government-issued ID details (e.g., PhilSys ID, passport, driver's licence, SSS/GSIS ID).

Financial Data:

• GCash or PayMaya/Maya account reference (not your full wallet credentials).
• Bank account details for withdrawal processing (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank).
• Transaction history including deposits, withdrawals, and gaming activity.

Technical & Usage Data:

• IP address, device type, browser type, and operating system.
• Login timestamps, session duration, and pages visited on the Platform.
• Game play history, bet amounts, and wagering patterns.
• Cookie identifiers and similar tracking technologies (see Section 10).

Communications Data:

• Records of your communications with jlttt customer support via live chat or email.
• Feedback, survey responses, and promotional opt-in preferences.

jlttt collects personal data through the following means:

• Direct collection: Information you provide when registering, completing KYC verification, making deposits or withdrawals, or contacting support.
• Automated collection: Technical data collected automatically when you access the Platform, including via cookies, log files, and analytics tools.
• Third-party sources: Identity verification data from KYC service providers; payment data from GCash, PayMaya, and banking partners; fraud prevention data from compliance service providers.
• PAGCOR reporting: Data shared with or received from PAGCOR as required by Philippine gaming regulations and anti-money laundering laws.

jlttt uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your jlttt account.
• Identity verification: Conducting KYC checks to verify your age (21+) and identity as required by PAGCOR.
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers.
• Regulatory compliance: Meeting obligations under PAGCOR regulations, the Philippine Anti-Money Laundering Act (AMLA), and the Data Privacy Act.
• Fraud prevention: Detecting and preventing fraudulent activity, money laundering, and abuse of the Platform.
• Customer support: Responding to your queries, resolving disputes, and improving support quality.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling and applying responsible gaming tools where appropriate.
• Platform improvement: Analysing usage data to improve the jlttt Platform, game library, and user experience.
• Marketing communications: Sending you promotional offers, bonuses, and news about jlttt — only where you have opted in or where permitted by law.

jlttt processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: Processing required to fulfil our obligations under the jlttt Terms & Conditions, including account management and payment processing.
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA reporting requirements, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.

jlttt does not sell, rent, or trade your personal data. We may share your data only in the following limited circumstances:

• PAGCOR and Philippine regulators: As required by law, jlttt reports certain player data and transaction records to PAGCOR and other relevant Philippine government agencies.
• Payment processors: GCash, PayMaya/Maya, and Philippine banking partners receive only the data necessary to process your transactions.
• KYC and identity verification providers: Third-party providers who assist with age and identity verification receive data solely for that purpose and are bound by strict confidentiality obligations.
• Fraud prevention and compliance services: Service providers who assist jlttt in detecting fraud, money laundering, and regulatory breaches.
• Legal proceedings: Where required by a valid court order, subpoena, or other legal process under Philippine law.

jlttt retains your personal data for as long as your account is active and for a period thereafter as required by Philippine law and PAGCOR regulations. Specific retention periods include:

• Account and KYC data: Retained for a minimum of five (5) years after account closure, as required by PAGCOR and AMLA regulations.
• Transaction records: Retained for a minimum of five (5) years in accordance with Philippine anti-money laundering requirements.
• Customer support records: Retained for three (3) years after the resolution of the relevant query or dispute.
• Marketing data: Retained until you withdraw consent or opt out, after which it is deleted within thirty (30) days.

Upon expiry of the applicable retention period, jlttt will securely delete or anonymise your personal data in accordance with the Data Privacy Act.

jlttt implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jlttt servers.
• Encrypted storage of sensitive personal and financial data at rest.
• Multi-factor authentication options for player accounts.
• Access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits and penetration testing of the jlttt Platform.
• Incident response procedures to detect, contain, and notify affected players of any data breach in accordance with the Data Privacy Act's 72-hour notification requirement.

While jlttt takes all reasonable steps to protect your data, no electronic system is completely immune to security risks. You are responsible for maintaining the confidentiality of your jlttt Login credentials.

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

• Right to be informed: The right to know what personal data jlttt collects and how it is used — as set out in this Policy.
• Right of access: The right to request a copy of all personal data jlttt holds about you.
• Right to rectification: The right to correct inaccurate or incomplete personal data in your jlttt account.
• Right to erasure: The right to request deletion of your personal data, subject to legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact the jlttt Data Privacy Officer at [email protected]. jlttt will respond to all verified data rights requests within thirty (30) days.

jlttt uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse usage patterns. The types of cookies used include:

• Essential cookies: Required for the Platform to function, including session management and security. These cannot be disabled.
• Analytics cookies: Used to understand how players use the jlttt Platform so we can improve it. These are anonymised and aggregated.
• Preference cookies: Used to remember your language, display, and notification preferences.
• Marketing cookies: Used to deliver relevant jlttt promotions. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use the core jlttt Platform features.

The jlttt Platform is strictly intended for individuals aged 21 years and above, as required by PAGCOR regulations. jlttt does not knowingly collect personal data from persons under 21. If we become aware that a person under 21 has provided personal data to jlttt, we will immediately close the account, delete the data, and report the matter to PAGCOR as required by law.

If you are a parent or guardian and believe your child has accessed the jlttt Platform, please contact us immediately at [email protected].

jlttt reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered players via email or a prominent notice on the Platform. The "Last Updated" date at the top of this Policy reflects the most recent revision. Continued use of the jlttt Platform following notification of any change constitutes acceptance of the revised Policy.

For any questions, concerns, or data rights requests relating to this Privacy Policy, please contact the jlttt Data Privacy Officer: