jlmine Casino – Privacy Policy

1. Identity of the Personal Information Controller

For the purposes of the Philippine Data Privacy Act of 2012 (DPA) and its Implementing Rules and Regulations, jlmine — the operator of the online gaming platform accessible at jlmine.app — is the Personal Information Controller (PIC) in respect of all personal data collected from players, prospective players, and visitors to the Platform.

jlmine operates under a licence issued by the Philippine Amusement and Gaming Corporation (PAGCOR). As a PAGCOR-licensed operator, jlmine is subject to PAGCOR's data governance requirements in addition to the DPA, and processes player data in a manner consistent with both regulatory frameworks.

2. Categories of Personal Data We Collect

jlmine collects personal data through the following channels: account registration, KYC verification submissions, platform usage, payment transactions, customer support interactions, and technical session data. The categories of data collected include:

jlmine does not collect sensitive personal information as defined under Section 3(l) of the DPA (such as racial or ethnic origin, political opinions, religious beliefs, health data, or sexual life) except where age and identity verification incidentally touches on such categories through government ID review, in which case only the minimum necessary data is retained.

3. Legal Basis for Processing

jlmine processes your personal data on the following legal bases under the DPA and its IRR:

• Contractual Necessity: Processing is necessary for the performance of the player account agreement — including registration, account management, deposit and withdrawal processing, game participation, and customer support.
• Legal Obligation: Processing is required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA, Republic Act No. 9160 as amended), and other applicable Philippine regulatory obligations, including mandatory KYC and transaction reporting.
• Legitimate Interests: Processing is necessary for jlmine's legitimate interests in fraud prevention, platform security, responsible gaming enforcement, and improvement of the Platform, provided such interests are not overridden by your fundamental rights.
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given and withdrawable consent obtained at the point of collection.

4. How jlmine Uses Your Personal Data

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

• Account Management: Creating and maintaining your jlmine Account, verifying your identity and age (21+), processing login authentication including OTP delivery, and managing account settings.
• Payment Processing: Facilitating deposits via GCash, PayMaya, BPI, BDO, and Metrobank; processing withdrawal requests; reconciling transactions; and complying with AMLA reporting thresholds.
• Regulatory Compliance: Meeting PAGCOR licensing conditions, completing mandatory KYC verification, filing reports required under AMLA, and responding to lawful requests from Philippine government authorities.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviour, enforcing deposit limits and self-exclusion requests, and providing mandated responsible gaming interventions.
• Fraud Prevention & Security: Detecting and preventing fraudulent account activity, unauthorised access, money laundering, bonus abuse, and technical attacks on the Platform.
• Platform Improvement: Analysing aggregated usage data to improve game offerings, payment flows, and platform performance for Filipino players.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to Players who have consented to receive such communications. You may withdraw consent at any time via your account notification settings.

5. Data Sharing & Third-Party Disclosure

jlmine does not sell, rent, or trade your personal data to third parties for their own marketing purposes. jlmine may share your personal data with the following categories of recipients on a strictly need-to-know basis:

• PAGCOR and Philippine Government Authorities: As required by jlmine's operating licence and applicable law, including mandatory reporting under AMLA and responses to lawful regulatory or law enforcement requests.
• Payment Service Providers: GCash, PayMaya, BPI, BDO, and Metrobank receive the minimum personal data necessary to process your deposit and withdrawal transactions. These providers are subject to their own regulatory obligations and privacy policies.
• Game Content Providers: Third-party game software providers may receive pseudonymised session identifiers and game-event data necessary to operate certified game RNG systems and live dealer feeds. They do not receive your full identity data.
• KYC Technology Providers: Identity verification service providers that process government ID images and biometric confirmation on jlmine's behalf under strict data processing agreements compliant with the DPA.
• Information Security Providers: Fraud detection and cybersecurity vendors that process technical session data (IP addresses, device fingerprints) to protect Platform integrity.

All third-party service providers acting as Personal Information Processors on jlmine's behalf are bound by written agreements that require them to process data only on jlmine's documented instructions and to implement security measures appropriate to the data they handle.

jlmine does not transfer your personal data outside the Philippines except where required to provide the Platform services and subject to appropriate safeguards. Where cross-border data transfers occur, they are conducted in accordance with Section 21 of the DPA and NPC Circular 16-01.

6. Cookies & Session Tracking Technologies

The jlmine Platform uses the following categories of cookies and similar tracking technologies:

• Strictly Necessary Cookies: Required for the Platform to function — including login session management, security tokens, and language preference storage. These cannot be disabled without impairing Platform functionality.
• Performance & Analytics Cookies: Aggregate and anonymised data on how players navigate the Platform, which pages are visited most, and where technical errors occur. Used solely to improve Platform performance.
• Functional Cookies: Remember your display preferences, game lobby filters, and responsible gaming limit settings between sessions.
• Marketing Cookies: Used only where you have provided explicit consent to receive personalised promotional communications. You may withdraw consent via your account notification settings at any time.

You may manage cookie preferences through your browser settings. Blocking strictly necessary cookies will prevent login and Platform access.

7. Data Retention

jlmine retains personal data for the following minimum periods, after which data is securely deleted or irreversibly anonymised:

• Account and KYC Records: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AMLA record-keeping obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with AMLA and Bureau of Internal Revenue requirements.
• Gaming Activity Logs: Retained for three (3) years following the recorded session, for dispute resolution and responsible gaming audit purposes.
• Customer Support Communications: Retained for two (2) years following resolution of the relevant support interaction.
• Marketing Consent Records: Retained for the duration of the consent period and for one (1) year following withdrawal, as evidence of the consent obtained.

Where retention beyond these periods is required by a specific legal obligation, court order, or regulatory direction, jlmine will retain the relevant data for the duration required and delete it promptly thereafter.

8. Security Measures

jlmine implements technical and organisational security measures appropriate to the nature, scope, and purposes of the personal data it processes. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jlmine servers.
• Encryption at rest for all personal data stored in jlmine databases, including KYC documents and financial records.
• Role-based access controls limiting internal employee access to personal data on a strict need-to-know basis.
• Multi-factor authentication required for all jlmine administrative system access.
• Regular independent penetration testing of the Platform and associated infrastructure.
• 24/7 automated monitoring for anomalous access patterns and potential data breach indicators.
• Documented incident response procedures aligned with the NPC's mandatory 72-hour breach notification requirement.

In the event of a personal data breach that is likely to result in serious harm to affected individuals, jlmine will notify the National Privacy Commission (NPC) within 72 hours of discovery and will communicate with affected Players as required by NPC Circular 16-03.

9. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you are entitled to exercise the following rights in respect of your personal data held by jlmine:

• Right to Be Informed: To know that your personal data is being collected, the purposes for which it is processed, and your rights under the DPA.
• Right of Access: To obtain a copy of your personal data held by jlmine in a portable, readable format.
• Right to Rectification: To have inaccurate or incomplete personal data corrected or updated.
• Right to Erasure or Blocking: To request deletion or blocking of your personal data where processing is no longer necessary, where consent has been withdrawn, or where data has been unlawfully processed — subject to jlmine's overriding legal retention obligations.
• Right to Data Portability: To receive a structured, machine-readable copy of your personal data for transmission to another controller, where technically feasible.
• Right to Object: To object to processing based on legitimate interests, in particular to direct marketing processing.
• Right to File a Complaint: To lodge a complaint with the National Privacy Commission (NPC) if you believe jlmine has violated your rights under the DPA.

To exercise any of the above rights, contact jlmine's Data Protection Officer using the contact details in Section 12. Requests will be acknowledged within 72 hours and actioned within 30 days, subject to identity verification and legal retention requirements.

10. Minors & Age Restriction

The jlmine Platform is strictly for individuals aged 21 years and above in compliance with PAGCOR regulations and Philippine gaming law. jlmine does not knowingly collect personal data from individuals under 21. Age is verified through government ID submission during the KYC process, and accounts found to be held by individuals under 21 will be immediately closed and all associated data deleted except where retention is required by law.

If you become aware that a minor has submitted personal data to jlmine, please contact our Data Protection Officer immediately at the contact details in Section 12.

11. Changes to This Privacy Policy

jlmine reserves the right to update this Privacy Policy to reflect changes in applicable law, PAGCOR regulatory requirements, or jlmine's data processing practices. Material changes will be communicated to registered Players via email to their registered address and/or via a prominent Platform notification, no fewer than seven (7) days before the updated Policy takes effect.

The effective date at the top of this Policy indicates when the current version took effect. Continued use of the jlmine Platform after the effective date of an updated Policy constitutes acceptance of the revised terms. If you do not accept a material change, you should close your Account before the effective date.

12. Contact & Data Protection Officer

For all privacy-related enquiries, data subject rights requests, or to contact jlmine's designated Data Protection Officer, please use the following channels:

• Email: [email protected] (plain text — not a clickable link) — subject line: "Privacy / DPO Request"
• Live Chat: Available through the dashboard of any verified jlmine Account, 24 hours a day. For data subject rights requests via live chat, the agent will create a formal ticket and provide a reference number.

jlmine's Data Protection Officer will acknowledge written requests within 72 hours and provide a substantive response within 30 calendar days. Where a request requires additional time due to complexity or volume, jlmine will notify you within the initial 30-day period and provide a revised timeline not exceeding 60 days in total.

You also have the right at any time to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe your data protection rights have not been respected. Information on how to contact the NPC is published on the NPC's official government website.