18jll Privacy Policy

01Who We Are

18jll ("we," "us," "our," or "the Company") operates the online gaming platform accessible at https://18jll.net and all associated mobile browser interfaces (collectively, the "Platform"). We are a Philippine-registered online gaming operator operating under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR).

This Privacy Policy applies to all personal information that 18jll collects, processes, stores, and discloses in connection with your use of the Platform, including when you register an account, make deposits or withdrawals, participate in games, contact our customer support team, or interact with any features of the 18jll platform. This Policy should be read together with our Terms and Conditions.

02Data We Collect

18jll collects personal information through a variety of means — directly from you during registration and account use, automatically through your interaction with the Platform, and from trusted third-party sources where permitted by law. The categories of data we collect include:

2.1 Identity and Registration Data

When you create a 18jll account, we collect your full legal name, date of birth, gender, nationality, and a copy of a valid government-issued photo identification document (such as a Philippine passport, SSS ID, UMID, PhilSys National ID, or driver's license). This data is required to verify your identity, confirm your eligibility to play (21+ only), and comply with our Know Your Customer (KYC) obligations.

2.2 Contact Information

We collect your email address, mobile phone number, and residential address (including city, province, and postal code). These are used for account communications, transaction notifications, support correspondence, and to send you promotional offers where you have given consent.

2.3 Financial and Transaction Data

To process deposits and withdrawals, we collect payment-related information including your GCash mobile number, PayMaya account details, bank account details (BPI, BDO, or Metrobank), or Visa card details. We do not store full card numbers in our systems — card data is handled through PCI-DSS compliant payment processors.

2.4 Gaming Activity Data

We automatically record your gaming history, including games played, wagers placed, wins and losses, bonus activations, session durations, and betting patterns. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory reporting.

2.5 Technical and Device Data

When you access 18jll, we automatically collect technical information about your device and connection, including your IP address, browser type and version, operating system, device identifiers, screen resolution, time zone settings, and referring URLs. This helps us optimize platform performance and detect fraudulent access.

2.6 Communications Data

If you contact our support team via email or live chat, we retain records of that correspondence, including the content of your messages, support ticket references, and the dates and times of communications. These records are maintained for quality assurance, dispute resolution, and training purposes.

03How We Use Your Data

18jll uses the personal information we collect for the following purposes:

Purpose	Data Used
Account creation and management	Identity data, contact information
Identity verification (KYC) and age verification (21+)	Identity data, government ID documents
Processing deposits and withdrawals	Financial data, identity data
Providing and improving gaming services	Gaming activity data, technical data
Anti-money laundering (AML) monitoring	Financial data, identity data, gaming activity
Fraud detection and prevention	Technical data, transaction data, gaming activity
Customer support	Contact information, communications data
Responsible gaming tools and monitoring	Gaming activity data, account data
Marketing and promotions (with consent)	Contact information, gaming preferences
Regulatory reporting to PAGCOR and NPC	Identity data, financial data, activity logs

We do not use your personal data for automated decision-making or profiling that produces significant legal effects, except where required by AML regulations or responsible gaming obligations. Where automated monitoring flags an account for review, a human review process follows before any account restriction is applied.

04Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), 18jll processes your personal data on the following legal bases:

• Consent: Where you have expressly agreed to the processing of your data for specific purposes, such as receiving promotional communications or subscribing to platform updates. You may withdraw consent at any time by contacting our Data Protection Officer.
• Contractual Necessity: Processing that is necessary to perform our obligations under the Terms and Conditions you agreed to when registering your 18jll account — including account management, payment processing, and providing gaming services.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including the Anti-Money Laundering Act (RA 9160), PAGCOR licensing requirements, tax obligations, and National Privacy Commission directives.
• Legitimate Interests: Processing necessary for the legitimate interests of 18jll, such as fraud prevention, platform security, responsible gaming monitoring, and business analytics — provided these interests are not overridden by your rights and freedoms.

05Sharing Your Data

18jll does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment processors and e-wallet providers (GCash, PayMaya, partner banks) — to facilitate deposit and withdrawal transactions.
• Identity verification and KYC service providers — to validate your identity documents and confirm eligibility.
• IT infrastructure and cloud service providers — who host and maintain our platform systems under strict data processing agreements.
• Fraud prevention and security vendors — who assist in detecting and preventing unauthorized access, cheating, and financial crime.
• Regulatory bodies — including PAGCOR and the Anti-Money Laundering Council (AMLC) of the Philippines, where disclosure is required by law or court order.
• Legal and professional advisors — such as lawyers and auditors, bound by professional confidentiality obligations.

All third-party service providers who process personal data on behalf of 18jll are required to enter into Data Sharing Agreements or Data Processing Agreements that impose privacy and security obligations consistent with this Policy and the Philippine Data Privacy Act of 2012.

06Cookies & Tracking Technologies

6.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the 18jll platform. They help us recognize your browser, remember your preferences, maintain your logged-in session, and analyze how the platform is being used. We also use similar technologies such as pixel tags and local storage.

6.2 Types of Cookies We Use

• Essential Cookies: Required for the platform to function correctly. These include session authentication cookies and security tokens. You cannot opt out of essential cookies while using the platform.
• Functional Cookies: Remember your preferences such as language settings and game history, to provide a more personalized experience.
• Analytics Cookies: Help us understand how players navigate the platform, which games are most popular, and where technical issues occur, allowing us to continuously improve the user experience.
• Marketing Cookies: Used to deliver promotional content relevant to your interests, both on the 18jll platform and through partner channels, where you have consented to marketing communications.

6.3 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to refuse cookies, delete existing cookies, or receive alerts before a cookie is placed. Please note that disabling certain cookies may affect the functionality of the 18jll platform, including your ability to stay logged in or access certain game features.

07Data Retention

18jll retains your personal data for as long as your account remains active and for a reasonable period thereafter, in accordance with the following retention guidelines:

• Account and identity data: Retained for a minimum of five (5) years after account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act of the Philippines.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine tax and AML regulations.
• Gaming activity logs: Retained for three (3) years from the date of each gaming session, for dispute resolution and regulatory audit purposes.
• Customer support communications: Retained for two (2) years from the date of resolution of the relevant support case.
• Marketing consent records: Retained for the duration of your account and for three (3) years thereafter to demonstrate compliance with consent requirements.

After the applicable retention period expires, personal data is securely deleted or anonymized so that it can no longer be associated with you. Where anonymized data is retained for analytical purposes, it is no longer considered personal information under the Data Privacy Act.

08Data Security

18jll implements a comprehensive set of technical and organizational security measures designed to protect your personal information against unauthorized access, loss, destruction, alteration, or disclosure. Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption at rest for sensitive personal data and financial records stored in our databases.
• Multi-factor authentication options for player account login.
• Role-based access controls ensuring that only authorized 18jll personnel can access personal data, strictly on a need-to-know basis.
• Regular third-party penetration testing and security audits of our platform infrastructure.
• 24/7 automated monitoring for suspicious access patterns, intrusion attempts, and anomalous transaction behavior.
• Secure data centers with physical access controls and environmental safeguards.

Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in serious harm to affected individuals, 18jll will notify the National Privacy Commission (NPC) and affected players in accordance with the timelines and procedures prescribed under the Philippine Data Privacy Act and NPC Circular No. 16-03.

09Your Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 18jll:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and shared — which is the purpose of this Privacy Policy.
• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to Rectification: If any personal data we hold is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure or Blocking: In certain circumstances, you have the right to request the deletion or suspension of processing of your personal data — for example, where the data is no longer necessary for the purposes it was collected, or where you withdraw consent. Note that this right may be limited by our legal obligations to retain data under Philippine law.
• Right to Data Portability: You may request your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though we may demonstrate compelling grounds that override your objection.
• Right to Lodge a Complaint: If you believe that 18jll has violated your privacy rights, you may file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer (DPO) at [email protected] with the subject line "Privacy Rights Request." We will respond to your request within fifteen (15) business days. We may ask you to verify your identity before processing your request.

10Children's Privacy

The 18jll platform is strictly intended for individuals who are at least 21 years of age, in compliance with Philippine gaming laws and PAGCOR regulations applicable to casino-style wagering. We do not knowingly collect personal information from anyone under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age without verifiable parental consent and in violation of our age restriction policy, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on our platform, please contact us immediately at [email protected].

11Cross-Border Data Transfers

18jll primarily stores and processes your personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers and certain software vendors — may be located outside of the Philippines and may process your data in other jurisdictions.

Where personal data is transferred outside of the Philippines, 18jll takes steps to ensure that adequate protections are in place, including requiring the receiving party to be bound by data protection obligations at least equivalent to those under the Philippine Data Privacy Act of 2012. Such transfers are conducted pursuant to duly executed data transfer agreements and are subject to prior notification to or approval from the National Privacy Commission where required.

12Third-Party Links

The 18jll platform may contain references to third-party services such as payment gateways. Once you navigate away from 18jll to a third-party website or service, this Privacy Policy no longer applies. 18jll is not responsible for the privacy practices of third-party sites and encourages you to review their respective privacy policies before providing any personal information.

13Updates to This Policy

18jll reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or platform features. When material changes are made, we will notify registered players via the email address on file and display a prominent notice on the platform for a reasonable period following the update. The effective date at the top of this Policy will be updated accordingly.

Your continued use of the 18jll platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you should cease using the platform and may request account closure in accordance with our Terms and Conditions.

14Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 18jll handles your personal data, please contact our designated Data Protection Officer (DPO):

• Email: [email protected]
• Subject Line: Privacy Policy Inquiry / DPO Request
• Response Time: Within 15 business days of receiving your request
• Support Hours: 24 hours a day, 7 days a week, Philippine Standard Time (PST, UTC+8)

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at [email protected] or by visiting privacy.gov.ph.