ljljl Privacy Policy

1 Introduction

ljljl ("ljljl," "we," "us," or "our") operates the online gaming platform accessible at ljljl.org. We are committed to protecting the personal information of every Filipino player who registers and plays on our platform. This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal data in connection with your use of the ljljl platform, including all games, features, and services offered therein.

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines. It is also consistent with the regulatory requirements of the Philippine Amusement and Gaming Corporation ("PAGCOR") applicable to licensed online gaming operators.

By registering an ljljl account or continuing to use the platform, you acknowledge that you have read, understood, and consent to the practices described in this Policy. If you do not agree with any part of this Policy, please discontinue use of the ljljl platform and contact our support team to close your account.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, ljljl is the personal information controller ("PIC") in respect of personal data collected from players and visitors to the ljljl platform. As a PIC, ljljl determines the purposes and means of processing your personal data and is accountable for ensuring that all processing activities comply with the DPA and its Implementing Rules and Regulations.

ljljl has designated a Data Protection Officer ("DPO") responsible for overseeing data privacy compliance and acting as the point of contact for all data privacy-related inquiries, requests, and complaints. You may reach our DPO at the contact details provided in Section 14 of this Policy.

3 Personal Data We Collect

ljljl collects only the personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is processed. The categories of personal data we collect include:

ljljl does not intentionally collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. Where sensitive personal information — such as government ID numbers — is collected, it is handled with additional safeguards as described in Section 9 of this Policy.

4 How We Collect Your Data

ljljl collects personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, or update your account settings.
• Automatically — through cookies, web beacons, log files, and similar tracking technologies as you browse and interact with the ljljl platform. See Section 10 for our Cookies Policy.
• From payment processors — GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers may share transaction confirmation data and account verification information with us to process your deposits and withdrawals.
• From identity verification providers — we work with third-party KYC service providers who assist in verifying the authenticity of the identification documents you submit.
• From regulatory authorities — PAGCOR and other Philippine government agencies may share information with us in connection with licensing compliance, anti-money laundering obligations, or fraud investigations.

5 Purpose of Processing

ljljl processes your personal data for the following purposes:

• To register and maintain your ljljl player account, including verifying your identity and eligibility to use the platform.
• To process your financial transactions, including deposits via GCash, PayMaya, and Philippine banks, and withdrawals to your verified payment account.
• To comply with PAGCOR licensing requirements, including player registration records, gaming transaction logs, and anti-money laundering reporting obligations under Republic Act No. 9160 (Anti-Money Laundering Act) as amended.
• To provide customer support and respond to your inquiries, complaints, and requests in a timely manner.
• To administer bonuses, promotions, loyalty programmes, and any other promotional activities you opt into.
• To ensure the security, integrity, and fair operation of the ljljl platform, including fraud detection, collusion prevention, and abuse detection.
• To operate our responsible gaming programme, including administering deposit limits, loss limits, session reminders, and self-exclusion requests you initiate.
• To send you service notifications, account alerts, security notices, and — where you have given consent — marketing communications about ljljl promotions and new features.
• To analyse platform usage patterns and improve the ljljl experience for all Filipino players, including players in Manila, Cebu, Davao, Quezon City, Makati, and across Luzon, Visayas, and Mindanao.
• To comply with any other applicable Philippine law, regulation, or court order.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, ljljl processes your personal data on one or more of the following lawful bases:

• Consent — You have given your free, specific, informed, and unambiguous consent by registering an ljljl account and agreeing to this Policy. You may withdraw consent at any time, subject to the consequences described below.
• Contractual Necessity — Processing is necessary to perform the contract between you and ljljl (your account registration and use of gaming services), or to take steps at your request before entering into that contract.
• Legal Obligation — Processing is required for ljljl to comply with its obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests — Processing is necessary for the purposes of ljljl's legitimate interests — such as platform security, fraud prevention, and service improvement — except where such interests are overridden by your rights and freedoms.

Where processing is based on your consent, you have the right to withdraw that consent at any time by contacting our Data Protection Officer. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. Please note that withdrawing consent for processing that is necessary for account operation may result in the closure of your ljljl account.

7 Data Sharing & Disclosure

ljljl does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We may share your personal data only in the following circumstances and only to the extent strictly necessary:

• Payment Service Providers — GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors receive the minimum financial and identity data required to execute your deposit and withdrawal transactions securely.
• KYC & Identity Verification Partners — Third-party verification services receive your identification documents and identity data solely for the purpose of confirming your eligibility and identity as required by PAGCOR.
• Game Content Providers — Live casino studio operators and RNG game providers may receive session data necessary for gameplay, dispute resolution, and game integrity auditing. They do not receive your financial or contact data.
• Regulatory Authorities — PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission, and other competent Philippine authorities may receive personal data where required by law, regulation, court order, or as part of a lawful investigation.
• Professional Advisors — Our legal counsel, auditors, and compliance advisors may access personal data on a need-to-know basis and are bound by professional confidentiality obligations.
• Business Transfers — In the event of a merger, acquisition, or sale of substantially all of ljljl's assets, player data may be transferred to the successor entity, subject to equivalent data protection commitments.

All third parties with whom ljljl shares personal data are required to process that data in accordance with the Data Privacy Act of 2012 and are bound by appropriate data processing agreements or contractual confidentiality obligations.

8 Data Retention

ljljl retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Active Account Data — Retained for the duration of your account relationship with ljljl and for five (5) years following permanent account closure, in compliance with PAGCOR record-keeping requirements.
• Financial Transaction Records — Retained for a minimum of five (5) years from the date of the transaction, in accordance with AMLC regulations and generally accepted accounting standards applicable in the Philippines.
• KYC Verification Documents — Retained for five (5) years after account closure or the last transaction, whichever is later.
• Support Communications — Retained for three (3) years from the date of the communication, or longer where relevant to an ongoing dispute or investigation.
• Technical & Usage Logs — Retained for a maximum of twelve (12) months in standard circumstances unless flagged in connection with a security incident or regulatory inquiry.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be associated with any identifiable individual.

9 Data Security Measures

ljljl implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security programme includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ljljl platform.
• Encryption at rest for databases containing sensitive personal data and identification documents.
• Role-based access controls ensuring that ljljl staff can only access personal data that is necessary for their specific job function.
• Two-factor authentication requirements for all ljljl internal systems that handle player data.
• Regular security vulnerability assessments and penetration testing conducted by independent security professionals.
• Comprehensive audit logs of all internal access to personal data, reviewed regularly by our security and compliance teams.
• Staff data privacy training and confidentiality obligations as part of employment and contractor agreements.

While ljljl employs industry-standard safeguards, no method of electronic transmission or storage is completely secure. You are responsible for keeping your account credentials confidential and for notifying ljljl immediately upon becoming aware of any unauthorised access to your account.

10 Cookies & Tracking Technologies

The ljljl platform uses cookies and similar tracking technologies to deliver, maintain, and improve the platform experience. A cookie is a small text file placed on your device by our web server when you visit the platform. We use the following categories of cookies:

• Strictly Necessary Cookies — Essential for the platform to function. These include session authentication cookies that keep you logged in during your visit and security cookies that protect against cross-site request forgery. These cookies cannot be disabled.
• Functional Cookies — Remember your preferences, such as language settings, game display preferences, and responsible gaming tool configurations, to provide a more personalised experience.
• Analytics Cookies — Help us understand how players use the ljljl platform, which pages are most popular, and where technical errors occur. Data collected is aggregated and does not identify individual players. We use this data solely to improve the platform.
• Session Cookies — Temporary cookies that expire when you close your browser, used to maintain your session state during a single visit to the platform.

You can manage cookie preferences through your browser settings. Please note that disabling cookies beyond strictly necessary ones may affect the functionality and performance of the ljljl platform. We do not use cookies to serve third-party advertising or share browsing data with advertisers.

11 Your Data Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ljljl. You may exercise any of these rights by contacting our Data Protection Officer using the details in Section 14:

ljljl will respond to all verified data privacy rights requests within thirty (30) calendar days of receipt. Where a request is complex or involves a high volume of data, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it. If you are not satisfied with ljljl's response to a data privacy rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

12 Protection of Minors

The ljljl platform is strictly intended for persons aged 21 years and above in accordance with PAGCOR regulations governing online gaming in the Philippines. ljljl does not knowingly collect personal data from individuals below the age of 21.

During registration, all applicants are required to declare their date of birth and agree that they meet the minimum age requirement. ljljl further verifies age through the KYC process using government-issued Philippine identification documents. Any account found to belong to a person under 21 years of age will be immediately suspended, all balances will be forfeited, and personal data collected in connection with that account will be securely deleted, except to the extent that retention is required for legal or regulatory compliance purposes.

If you believe that a person under 21 has registered on the ljljl platform, please contact our support team immediately at [email protected] so that we may investigate and take appropriate action.

13 Changes to This Privacy Policy

ljljl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or NPC guidance. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this Policy.
• Send an email notification to the registered email address of all active ljljl players no less than seven (7) days before the updated Policy takes effect.
• Display a prominent notice on the ljljl platform informing players of the nature of the change and the effective date.

Your continued use of the ljljl platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the amended Policy, you must discontinue use of the platform and may request account closure. We encourage you to review this Policy periodically to remain informed about how ljljl protects your personal data.

14 Contact Our Data Protection Officer

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