Privacy Policy —
98jl Online Casino Philippines

01 Introduction & Scope

This Privacy Policy ("Policy") is issued by 98jl ("98jl," "we," "us," or "our") and governs the collection, processing, storage, use, and disclosure of personal data provided by or collected from users ("Player," "you," or "your") who access, register on, or otherwise interact with the 98jl online gaming platform at 98jl.club.

This Policy applies to all personal data processed in connection with the 98jl platform, including data collected through the website, mobile-optimized web interface, customer support channels, payment processing, and promotional communications. It applies to players accessing 98jl from the Philippines and all other jurisdictions where the platform is legally accessible.

98jl is committed to compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the circulars and advisories issued by the National Privacy Commission (NPC). This Policy is written to be as clear and understandable as possible — not buried in paragraphs of legalese that nobody wants to read through.

02 Data Controller

98jl acts as the Personal Information Controller (PIC) in respect of all personal data collected through the platform, as defined under the Philippine Data Privacy Act of 2012. As PIC, 98jl determines the purposes for which and the means by which personal data is processed.

Where 98jl engages third-party service providers (e.g., game studios, payment processors, customer support software providers) to process personal data on its behalf, such providers act as Personal Information Processors (PIPs) and are contractually bound to process data only in accordance with 98jl's instructions and in compliance with applicable data protection law.

For all data privacy matters, requests, and complaints, players may contact 98jl's designated Data Protection Officer (DPO) via the support channels specified in Section 15 of this Policy.

03 Data We Collect

98jl collects the following categories of personal data, limited to what is necessary and proportionate for the purposes described in this Policy:

98jl does not knowingly collect sensitive personal information as defined by the DPA (such as racial or ethnic origin, religious beliefs, health data, or criminal history) unless strictly required for a specific compliance purpose and with your explicit consent.

04 How We Collect Data

98jl collects personal data through the following means:

• Direct submission: Information you provide when creating your account, completing KYC, depositing funds, contacting support, or updating your profile.
• Automated technical collection: Data collected automatically during your visit to the platform via server logs, session cookies, and analytics tools — including IP address, device identifiers, and navigation behavior.
• Payment processors: Transaction data received from GCash, PayMaya, BDO, BPI, Metrobank, UnionBank, and other integrated payment providers when you initiate a deposit or withdrawal.
• Identity verification providers: Data returned by third-party KYC platforms used to verify government-issued identification documents.
• AML screening services: Results of screening against politically exposed persons (PEP) lists and sanctions databases, where applicable.
• Game providers: Aggregated session and wagering data from game studios integrated into the 98jl platform.

05 How We Use Your Data

98jl processes your personal data for the following purposes:

• Account creation and management: To register, verify, maintain, and administer your 98jl player account.
• Identity verification and KYC: To confirm your identity, verify your age (21+), and satisfy PAGCOR-compliant know-your-customer requirements before processing withdrawals.
• Payment processing: To facilitate deposits and withdrawals via your chosen payment method, including fraud screening on transactions.
• Gaming operations: To provide access to games, record game outcomes, manage bonus crediting, and calculate real-money balances.
• Customer support: To respond to your queries, resolve disputes, investigate complaints, and maintain support records.
• Regulatory compliance: To fulfill obligations under PAGCOR guidelines, AML legislation, and any other applicable Philippine law, including reporting requirements.
• Responsible gaming monitoring: To monitor gaming patterns for indicators of problem gambling behavior and to administer self-exclusion or limit-setting tools at your request or on a mandatory basis where required.
• Platform security and fraud prevention: To detect, prevent, and investigate unauthorized account access, cheating, money laundering, and other prohibited conduct.
• Service improvement: To analyze aggregate, anonymized usage data to improve platform performance, game selection, and user experience.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or have an existing player relationship with 98jl. You may opt out of marketing communications at any time through your account settings or by contacting support.

06 Legal Basis for Processing

Under the Philippine Data Privacy Act, every processing of personal data must have a lawful basis. 98jl relies on the following lawful bases for its processing activities:

• Contract performance: Processing necessary to fulfill our obligations to you under the 98jl Terms & Conditions — including account management, payment processing, and game operation.
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine law.
• Consent: For marketing communications and certain optional data collection activities, where you have provided specific, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Legitimate interests: For fraud detection, platform security, responsible gaming monitoring, and service improvement — where such processing does not override your fundamental privacy rights.

07 Data Sharing & Disclosure

98jl does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. 98jl may disclose your personal data to the following categories of recipients only where necessary and subject to appropriate contractual safeguards:

• Game studio partners: Limited session and account data necessary to facilitate access to and proper functioning of third-party games within the 98jl lobby.
• Payment processors: GCash, PayMaya, BDO, BPI, Metrobank, UnionBank, and cryptocurrency processing services — receiving only the transaction data necessary to process your deposits and withdrawals.
• Identity verification providers: KYC service providers who process identity document data to verify your identity on our behalf.
• AML screening services: Providers who screen player details against sanctions lists and PEP databases as required under Philippine AML regulations.
• Customer support software: Platforms that host live chat and ticketing functionality, which may process communication data on our behalf.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities where disclosure is required by law, regulation, court order, or regulatory directive.
• Professional advisers: Legal, audit, and compliance advisers bound by professional confidentiality obligations, where access to your data is necessary to provide their services to 98jl.

All third-party service providers who process personal data on behalf of 98jl are required to enter into data processing agreements that bind them to process data only on 98jl's instructions, to maintain appropriate security measures, and to comply with applicable Philippine data protection law.

08 International Transfers

The operation of the 98jl platform may involve the transfer of certain personal data to service providers or game studios located outside the Philippines. Where such international transfers occur, 98jl ensures that:

• The receiving jurisdiction provides an adequate level of data protection as recognized under NPC guidelines, or
• Appropriate contractual safeguards are in place — including standard contractual clauses or equivalent binding instruments — to ensure your personal data receives protection comparable to that provided under the Philippine Data Privacy Act.

You may request information about the specific safeguards applied to international data transfers by contacting 98jl's Data Protection Officer as detailed in Section 15.

09 Data Retention

98jl retains personal data for as long as is necessary for the purpose for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account relationship with 98jl, and for a minimum of five (5) years following account closure — consistent with AMLA record-keeping requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AML legislation.
• KYC documentation: Retained for the duration of the account relationship and five (5) years post-closure.
• Gaming activity records: Retained for up to three (3) years from the date of activity for dispute resolution and responsible gaming monitoring purposes.
• Customer support communications: Retained for up to two (2) years from the date of the last interaction.
• Marketing consent records: Retained for as long as the consent remains valid and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, 98jl will securely delete or anonymize your personal data in a manner that prevents reconstruction or re-identification.

10 Security Measures

98jl implements a multi-layered approach to data security, combining technical, organizational, and procedural safeguards to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction:

• Encryption in transit: All data transmitted between your device and the 98jl platform is encrypted using 256-bit SSL/TLS protocols. The presence of HTTPS and the padlock indicator in your browser confirms this protection is active.
• Encryption at rest: Sensitive personal and financial data stored on 98jl's servers is encrypted at rest using current cryptographic standards.
• Access controls: Access to personal data is restricted to authorized personnel on a need-to-know basis, enforced through role-based access controls and regular access reviews.
• Two-factor authentication: 98jl supports optional 2FA via SMS OTP for player accounts, providing an additional layer of login security against unauthorized access.
• Monitoring and logging: Platform activity is monitored continuously for security anomalies, unauthorized access attempts, and suspicious transaction patterns.
• Vendor security assessments: Third-party service providers with access to personal data are subject to security assessments as part of the onboarding and contract renewal process.

While 98jl applies rigorous security measures, no digital system can guarantee absolute security. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 98jl will notify the National Privacy Commission and affected individuals in accordance with the timelines and procedures required under the Philippine Data Privacy Act.

11 Cookies & Tracking Technologies

98jl uses cookies and similar technologies (such as session tokens and local storage) on its platform. These technologies serve the following purposes:

• Session cookies (strictly necessary): Maintain your login session and game state while you are actively using the platform. These are deleted when you close your browser.
• Preference cookies (functional): Remember platform settings such as your preferred language, display options, and responsible gaming tool configurations.
• Analytics cookies (performance): Collect aggregated, anonymized data on platform usage patterns to help 98jl identify performance bottlenecks and improve the user experience. Individual player behavior is not linked to identifiable profiles for this purpose.
• Security cookies: Support fraud detection and login security functions, including session integrity verification and bot detection.

98jl does not deploy third-party advertising cookies or tracking pixels that serve ads on external platforms. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may affect the functionality of your 98jl account and gaming sessions.

12 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you are entitled to the following rights in respect of your personal data held by 98jl:

To exercise any of the above rights, submit a written request to 98jl through the live chat support channel or via the support email address specified in Section 15. 98jl will acknowledge your request within five (5) business days and provide a substantive response within fifteen (15) business days of receiving all information necessary to process the request.

Certain rights may be subject to limitations where compliance would conflict with 98jl's legal obligations — for example, 98jl cannot delete transaction records that must be retained under AML legislation even upon erasure request. Where such limitations apply, 98jl will explain the basis for the limitation in its response to your request.

If you are not satisfied with 98jl's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

13 Minors & Age Verification

The 98jl platform is strictly restricted to individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing online gaming in the Philippines. 98jl does not knowingly collect personal data from individuals below this minimum age.

Age verification is conducted as part of the registration and KYC process. Where 98jl discovers that personal data has been collected from a player who is below the age of 21, the following actions will be taken immediately:

• The player's account will be closed with immediate effect.
• Any funds in the account will be handled in accordance with applicable law and PAGCOR guidelines.
• All personal data collected from the underage individual will be deleted from 98jl's systems to the extent permitted by law.

If you have reason to believe that a minor has registered on 98jl or that personal data belonging to a minor is being held by the platform, please contact 98jl's support team immediately.

14 Policy Changes

98jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our processing activities, applicable law, or regulatory guidance. Material changes to this Policy will be communicated to registered players via a platform notification or account message prior to the changes taking effect, where practicable.

The "Effective Date" displayed at the top of this Policy reflects the date of the most recent revision. Your continued use of the 98jl platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease use of the platform and may close your account as described in our Terms & Conditions.

We recommend reviewing this Policy periodically. All previous versions of this Policy are available on request from 98jl's Data Protection Officer.

15 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 98jl, please contact our Data Protection Officer through the following channels:

• Live Chat Support: Available 24/7 through the 98jl platform. This is the fastest channel for data rights requests and privacy queries.
• Support Email: [email protected] (Plain text — not a clickable link. Copy and paste into your email client.)

If you are not satisfied with 98jl's handling of your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the independent supervisory authority responsible for enforcing the Data Privacy Act.

For the avoidance of doubt, 98jl's response to all formal data rights requests will be provided in writing within the timelines set out in Section 12 of this Policy.