jlgm's Six Core Privacy Commitments
These principles are the foundation of every data decision at jlgm. The full Privacy Policy below provides the complete legal detail underpinning each commitment.
jlgm collects only the personal data that is strictly necessary for account operation, PAGCOR compliance, KYC verification, and service delivery. We do not collect data speculatively or for purposes beyond what is disclosed in this Policy.
All personal data stored by jlgm is protected using 256-bit AES encryption at rest and 256-bit SSL/TLS encryption in transit. KYC documents are stored on isolated, access-controlled servers. jlgm conducts regular security audits against industry standards.
jlgm shares your data only with verified service partners necessary to deliver our platform — payment processors like GCash and Maya, game providers, and our KYC verification partner. We never sell personal data to marketers or data brokers.
jlgm's data processing operations are fully compliant with the Philippine Data Privacy Act of 2012 (Republic Act 10173), its Implementing Rules and Regulations, and the data handling requirements of PAGCOR's online gaming regulatory framework.
As a jlgm player and a data subject under RA 10173, you have the right to access, correct, delete, object to processing, and port your personal data. jlgm provides clear procedures for exercising each right, detailed in Section 10 of this Policy.
jlgm retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by Philippine law and PAGCOR obligations. Retention schedules for each data category are defined in Section 9 of this Policy.
- 01 Scope & Controller
- 02 Data We Collect
- 03 How We Collect Data
- 04 Purpose & Legal Basis
- 05 Cookies & Tracking
- 06 Third-Party Sharing
- 07 International Transfers
- 08 Data Security
- 09 Data Retention
- 10 Your Rights
- 11 Minors & Age Restriction
- 12 Marketing Communications
- 13 Changes to This Policy
- 14 Data Protection Officer
- 15 Contact & Complaints
Scope and Data Controller
1.1 This Privacy Policy governs the collection and processing of personal data by jlgm in connection with the jlgm Platform at jlgm.asia, including all features, services, and communications offered through the Platform.
1.2 For purposes of the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations, jlgm acts as the personal information controller with respect to the personal data of its registered players and Platform users. This means jlgm determines the purposes and means of personal data processing activities described in this Policy.
1.3 This Policy applies to personal data collected through the following channels:
- Account registration and profile completion on jlgm.asia.
- KYC identity verification submissions.
- Financial transactions, including deposits and withdrawal requests.
- Interactions with jlgm's customer support team via Live Chat or email.
- Participation in promotions, surveys, and jlgm loyalty programs.
- Technical data automatically collected during Platform use, including browser information and session data.
1.4 This Policy does not apply to third-party websites, game provider platforms, or payment service interfaces that may be linked to or embedded within the jlgm Platform. Each third-party service is governed by its own privacy practices.
Personal Data We Collect
2.1 jlgm collects the following categories of personal data from its players and Platform users:
Category A Registration & Identity Data
- Full legal name as it appears on your government-issued identification.
- Date of birth and age verification data.
- Registered Philippine mobile number.
- Email address (where provided).
- Chosen username and encrypted account password.
- Residential address (required for full KYC verification).
Category B KYC Verification Data
- Scanned copy or clear photograph of a valid Philippine government-issued ID (UMID, PhilSys ID, Driver's License, Passport, SSS ID, Voter's ID, or PRC ID).
- Selfie photograph submitted for facial verification.
- Proof of payment method ownership documents where required.
- KYC verification status and review history.
Category C Financial & Transaction Data
- Deposit and withdrawal transaction records, including amounts and timestamps.
- Payment method identifiers (e.g., registered GCash or Maya mobile number, bank account last digits).
- Wallet balance history.
- Chargeback and dispute records, where applicable.
Category D Gaming Activity Data
- Game session records, including games played, wager amounts, outcomes, and timestamps.
- Sports betting selections and results.
- Bonus and promotion participation history.
- Loyalty program tier and point accumulation data.
- Responsible gaming tool settings and activation records.
Category E Technical & Device Data
- IP address and geolocation data derived from IP.
- Browser type, version, and operating system.
- Device identifiers and screen resolution.
- Session duration, page navigation paths, and Platform interaction logs.
- Referral source data (how you arrived at jlgm.asia).
Category F Communications Data
- Records of customer support interactions via Live Chat and email.
- Complaint and dispute correspondence.
- Marketing preference settings and opt-in/opt-out records.
- Survey responses and feedback submissions.
How We Collect Your Personal Data
3.1 jlgm collects personal data through the following mechanisms:
Direct Collection: Most personal data is collected directly from you when you register an Account, complete KYC verification, make a deposit or withdrawal, contact jlgm's support team, or participate in a promotion. This data is provided voluntarily by you in the course of using the jlgm Platform.
Automated Collection: Certain technical and device data is collected automatically when you access the jlgm Platform, using cookies, session tokens, server logs, and similar tracking technologies. See Section 5 for a full description of jlgm's cookie practices.
Third-Party Sources: In limited circumstances, jlgm may receive personal data about you from third parties, including: payment processors confirming transaction details; KYC verification partners confirming identity document authenticity; and fraud prevention services flagging accounts for review. jlgm processes such third-party data solely for the purposes for which it was shared.
Purpose and Legal Basis for Processing
4.1 jlgm processes your personal data for the purposes and on the legal bases set out in the table below. All processing is carried out in compliance with the Philippine Data Privacy Act of 2012.
| Purpose | Data Categories Used | Legal Basis |
|---|---|---|
| Account registration and management | A, E | Contract performance |
| Age and identity verification (KYC) | A, B | Legal obligation (PAGCOR / RA 10173) |
| Processing deposits and withdrawals | A, C | Contract performance |
| Providing gaming services and features | A, D, E | Contract performance |
| Anti-money laundering (AML) compliance | A, B, C | Legal obligation (AMLA / PAGCOR) |
| Fraud detection and prevention | A, C, D, E | Legitimate interest |
| Customer support and dispute resolution | A, C, D, F | Contract performance / Legitimate interest |
| Responsible gaming monitoring | A, D | Legal obligation / Legitimate interest |
| Bonus and promotions administration | A, C, D | Contract performance |
| Platform analytics and improvement | E | Legitimate interest |
| Marketing communications (opted-in users) | A, D, F | Consent |
4.2 Where jlgm relies on legitimate interests as the legal basis for processing, it has assessed that its interests are not overridden by your interests or fundamental rights and freedoms, taking into account the nature of the data and the context of processing.
4.3 Where jlgm relies on your consent for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
Cookies and Tracking Technologies
5.1 jlgm uses cookies and similar tracking technologies on jlgm.asia to ensure the Platform functions correctly, maintain your login session, understand how users navigate the Platform, and improve the user experience. The following categories of cookies are used:
- Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that maintain your logged-in state and security cookies that protect against cross-site request forgery. These cookies cannot be disabled without affecting Platform functionality.
- Functional Cookies: Remember your preferences, such as language settings and game lobby display options. Disabling these cookies may reduce Platform personalization.
- Analytics Cookies: Allow jlgm to understand aggregate Platform usage patterns — page views, session durations, navigation paths — to improve Platform design and performance. Analytics data is aggregated and does not identify individual users.
- Security Cookies: Used to detect and prevent fraudulent login attempts, bot activity, and other security threats against Platform accounts.
5.2 jlgm does not use third-party advertising or behavioural tracking cookies. No user data is shared with advertising networks through cookie technology.
5.3 You may control cookie settings through your browser's privacy settings. Disabling strictly necessary cookies will impair your ability to use the jlgm Platform. Changes to cookie settings take effect on your next Platform session.
Third-Party Data Sharing
6.1 jlgm does not sell, rent, or otherwise transfer personal data to third parties for marketing, advertising, or commercial purposes. Personal data is shared with third parties only in the circumstances described below:
- Payment Processors: GCash (PayMaya/G-Xchange Inc.), Maya (Voyager Innovations), BPI, BDO, and other payment service providers receive the minimum personal and transaction data necessary to process deposits and withdrawals on your behalf. Each payment processor is subject to its own data protection obligations under Philippine law.
- KYC Verification Partner: jlgm uses a third-party identity verification service to process and authenticate KYC documents. This partner operates under a data processing agreement with jlgm and is prohibited from using your KYC data for any purpose other than verification services for jlgm.
- Game Providers: Game providers whose titles are offered on the jlgm Platform (e.g., Evolution Gaming, Pragmatic Play, PG Soft) receive session-level data necessary to deliver game functionality. Game providers do not receive your full identity data unless required for a specific regulated game feature.
- Regulatory Authorities: jlgm is required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities when required by applicable law, court order, or regulatory direction. jlgm will inform affected users of such disclosure where legally permissible.
- Fraud Prevention Services: jlgm may share limited data with industry-standard fraud prevention networks to detect and prevent account fraud, identity theft, and bonus abuse.
- Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by jlgm may access personal data on a need-to-know basis, subject to strict confidentiality obligations.
International Data Transfers
7.1 Some of jlgm's service providers, particularly game providers and infrastructure partners, may be located outside the Philippines. Where personal data is transferred to a country or territory outside the Philippines, jlgm ensures that such transfers are made subject to appropriate safeguards consistent with the requirements of the Data Privacy Act of 2012.
7.2 Appropriate safeguards for international data transfers include: standard contractual clauses incorporating data protection obligations; transfers to countries that have been assessed as providing an adequate level of data protection; or transfers that are necessary for the performance of a contract between jlgm and the data subject.
7.3 jlgm maintains records of all international data transfer arrangements and makes summaries available to users upon request submitted to jlgm's Data Protection Officer.
Data Security
8.1 jlgm implements a comprehensive set of technical and organizational security measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction. Key security measures include:
- Encryption at Rest: All personal data, KYC documents, and financial records stored on jlgm's servers are encrypted using 256-bit AES encryption.
- Encryption in Transit: All data transmitted between your browser and jlgm's servers is protected using TLS 1.2 or higher (256-bit SSL). Browser connections without TLS are rejected.
- Access Controls: Personal data is accessible only to jlgm personnel who have a legitimate need to access it for their role. Access is controlled through role-based permissions, multi-factor authentication requirements for internal systems, and comprehensive audit logging.
- Physical Security: jlgm's servers are hosted in certified data centers with physical access controls, environmental monitoring, and redundant power and network infrastructure.
- Penetration Testing: jlgm's Platform infrastructure undergoes regular third-party penetration testing and vulnerability assessments to identify and remediate security weaknesses.
- Incident Response: jlgm maintains a documented data breach response plan. In the event of a data breach affecting your personal data, jlgm will notify affected users and the National Privacy Commission (NPC) as required by RA 10173.
Data Retention
9.1 jlgm retains personal data for the minimum period necessary to fulfil the purposes described in this Policy, subject to longer retention requirements imposed by Philippine law and PAGCOR regulations.
| Data Category | Retention Period | Basis |
|---|---|---|
| Account & Identity Data | Duration of account + 5 years | AML obligations / PAGCOR requirements |
| KYC Documents | Duration of account + 5 years | PAGCOR and AMLC requirements |
| Financial Transaction Records | 10 years from transaction date | Anti-Money Laundering Act (RA 9160) |
| Gaming Activity Records | 3 years from account closure | PAGCOR audit requirements |
| Customer Support Records | 3 years from last interaction | Legitimate interest (dispute resolution) |
| Technical & Session Logs | 12 months from collection | Security monitoring / Fraud prevention |
| Marketing Consent Records | Until withdrawal of consent + 1 year | Legal obligation (consent proof) |
9.2 Following the expiry of the applicable retention period, jlgm will securely delete or anonymize personal data. Anonymized data, which cannot be used to identify any individual, may be retained indefinitely for statistical and analytical purposes.
Your Data Subject Rights
10.1 As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by jlgm:
Request a copy of the personal data jlgm holds about you and information about how it is processed.
Request correction of inaccurate or incomplete personal data held by jlgm.
Request deletion of your personal data where jlgm no longer has a legitimate basis for retaining it, subject to legal retention requirements.
Object to jlgm processing your personal data where we rely on legitimate interests or for direct marketing purposes.
Receive your personal data in a structured, commonly used, machine-readable format for transfer to another service provider.
Request that jlgm restricts processing of your personal data in certain circumstances, such as while you contest its accuracy.
10.2 To exercise any of the above rights, submit a written request to jlgm's Data Protection Officer via email at [email protected] with the subject line "Data Subject Rights Request." Include your full registered name, Account username, and a description of the right you wish to exercise. Identity verification will be required before processing your request.
10.3 jlgm will respond to data subject rights requests within thirty (30) calendar days of receipt of a verified request. Where requests are complex or voluminous, jlgm may extend this period by a further thirty (30) days, with prior notice to you.
Minors and Age Restriction
11.1 The jlgm Platform is strictly restricted to individuals who are twenty-one (21) years of age or older, as required by PAGCOR regulations. jlgm does not knowingly collect personal data from persons under the age of 21.
11.2 If jlgm becomes aware that it has collected personal data from a person under the age of 21 — whether through registration, KYC review, or any other means — jlgm will immediately suspend the associated Account, delete or return any deposited funds, and delete the personal data collected from that individual, subject only to retention requirements mandated by law.
11.3 If you believe that a person under the age of 21 has registered an Account on jlgm, please notify jlgm immediately via email at [email protected] or via jlgm's 24/7 Live Chat service.
Marketing Communications
12.1 jlgm may send you promotional communications — including information about new games, bonuses, special offers, and Platform updates — via SMS to your registered Philippine mobile number and/or email to your registered email address, but only where you have provided explicit consent to receive such communications.
12.2 Consent to receive marketing communications is collected as a distinct opt-in checkbox during registration. This consent is separate from acceptance of jlgm's Terms & Conditions and is not a prerequisite for Account registration or use of the Platform.
12.3 You may withdraw consent to marketing communications at any time by:
- Clicking the unsubscribe link included in any marketing email from jlgm.
- Updating your communication preferences in your Account Settings under Notifications.
- Contacting jlgm's support team via Live Chat or email requesting removal from marketing communications.
12.4 Withdrawal of consent to marketing communications does not affect your ability to continue using the jlgm Platform or receiving transactional communications (e.g., deposit confirmations, OTP codes, account security alerts) that are necessary for Platform operation.
Changes to This Privacy Policy
13.1 jlgm reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or changes in our Platform's services. The date of the most recent revision is displayed at the top of this page.
13.2 Material changes to this Privacy Policy — meaning changes that materially affect your rights or how jlgm processes your personal data — will be communicated to registered users via email to the registered email address and/or via a prominent notice on the jlgm Platform at least fourteen (14) calendar days before the changes take effect.
13.3 Your continued use of the jlgm Platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the revised Policy, you must cease using the Platform and request Account closure.
Data Protection Officer
14.1 In compliance with the Data Privacy Act of 2012 and NPC Circular 17-01, jlgm has appointed a Data Protection Officer (DPO) responsible for overseeing jlgm's compliance with data privacy laws and this Privacy Policy.
14.2 The jlgm Data Protection Officer may be contacted for:
- Questions or concerns about jlgm's personal data processing practices.
- Submission of data subject rights requests.
- Reporting suspected personal data breaches affecting your Account.
- Requests for information about international data transfer safeguards.
Contact and Complaints
15.1 If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a complaint about jlgm's data processing practices, please contact jlgm's Data Protection Officer as described in Section 14.
15.2 jlgm takes all privacy complaints seriously and will acknowledge receipt of your complaint within five (5) business days and provide a substantive response within thirty (30) calendar days.
15.3 If you are not satisfied with jlgm's response to your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through its official complaint procedure. The NPC is the independent government authority responsible for enforcing the Data Privacy Act of 2012.
15.4 For regulatory matters related to jlgm's gaming operations, you may also contact the Philippine Amusement and Gaming Corporation (PAGCOR) through official government channels.