jlhp Privacy Policy

This Privacy Policy ("Policy") describes how jlhp ("jlhp", "we", "us", "our"), operator of the online gaming platform at jlhp.one, collects, processes, uses, discloses, retains, and protects the personal data of users ("you", "your", "User", "Player") in connection with your use of the jlhp platform and all related services.

jlhp is committed to protecting your privacy and ensuring that your personal information is handled in a responsible, transparent, and lawful manner consistent with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

By registering an account on jlhp, making a deposit, accessing any game, or otherwise interacting with the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

For the purposes of the Data Privacy Act of 2012, jlhp is the personal information controller responsible for the personal data collected and processed in connection with your use of the Platform. jlhp operates under licensing issued by the Philippine Amusement and Gaming Corporation (PAGCOR), and certain data processing activities are conducted to fulfill the obligations imposed by PAGCOR's regulatory framework, including Know Your Customer (KYC) verification and transaction monitoring requirements.

Contact information for jlhp's Data Protection Officer is provided in Section 14 of this Policy. For all privacy-related inquiries, requests to exercise your data subject rights, or reports of suspected data privacy incidents, please direct your communication to the designated Data Protection Officer.

jlhp collects personal data through your direct interactions with the Platform, automated technical processes, and from third parties where permitted by law. The categories of personal data collected are described below.

3.1 Sensitive Personal Information

jlhp may process certain categories of sensitive personal information as defined under the Data Privacy Act, including national identification numbers as part of KYC verification. This data is processed under strict security controls and is accessed only by authorized compliance personnel. jlhp does not collect health information, political affiliations, religious beliefs, or financial information beyond what is directly required to operate your gaming account and comply with PAGCOR's anti-money laundering requirements.

jlhp processes personal data only for specified, explicit, and legitimate purposes. The purposes for which your personal data is used are set out below:

• Account Registration and Verification: To create and manage your jlhp account, verify your identity and age (21+), and comply with PAGCOR's KYC requirements for licensed operators.
• Platform Operation and Game Delivery: To provide access to all games, process bets and payouts, display account balances, and deliver the core gaming experience.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other approved methods; to verify payment authenticity; and to prevent unauthorized transactions.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal conduct. This includes automated risk scoring and transaction monitoring as required by PAGCOR's Anti-Money Laundering compliance framework.
• Regulatory Compliance: To fulfill reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine regulatory bodies as required by law.
• Responsible Gaming: To monitor gameplay patterns for signs of problem gambling, to apply responsible gaming tools activated by the player, and to implement mandatory safeguards where jlhp has reasonable cause for concern.
• Customer Support: To respond to your inquiries, resolve disputes, and process complaints submitted through jlhp's support channels.
• Platform Improvement: To analyze aggregated, anonymized usage data to improve platform performance, game selection, and user experience. Individual user data is not used for this purpose without anonymization.
• Promotional Communications: To send you marketing communications about jlhp promotions and bonuses where you have given consent and not subsequently withdrawn it. You may opt out of marketing communications at any time via your account settings or by contacting support.

jlhp processes your personal data under one or more of the following legal bases as applicable under the Data Privacy Act of 2012:

• Consent: Where you have given clear and informed consent, including consent to marketing communications and to the processing of sensitive personal information during KYC verification.
• Contractual Necessity: Where processing is necessary to fulfill jlhp's obligations under the Terms and Conditions accepted at registration — including account management, game delivery, and payment processing.
• Legal Obligation: Where processing is required to comply with applicable Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself.
• Legitimate Interests: Where processing is necessary for jlhp's legitimate business interests — including fraud prevention, platform security, and responsible gaming monitoring — provided those interests are not outweighed by your rights and freedoms.

jlhp does not sell, rent, or trade your personal data to any third party for commercial purposes. Personal data is shared only in the following circumstances:

6.1 Service Providers and Processors

jlhp engages third-party service providers who process personal data on jlhp's behalf under data processing agreements that require them to handle data in compliance with the Data Privacy Act. These include payment processors (GCash/Maya Philippines, BancNet, Visa/Mastercard acquiring partners), game providers operating certified gaming servers, identity verification service providers, and cloud infrastructure providers. These parties are permitted to use personal data only for the specific services they provide to jlhp.

6.2 Regulatory and Law Enforcement Disclosures

jlhp is required to disclose personal data to PAGCOR, the Anti-Money Laundering Council, the National Privacy Commission, the Bureau of Internal Revenue, and other competent Philippine government authorities when legally required to do so. Such disclosures are made only to the extent required by the applicable legal obligation and are not subject to your consent in such circumstances.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of jlhp's business or assets, personal data held by jlhp may be transferred to the relevant successor entity. You will be notified of such a transfer via the registered email address prior to your data becoming subject to a materially different privacy policy.

jlhp retains personal data for the minimum period necessary to fulfill the purposes for which it was collected, subject to longer retention where required by law. The following retention periods apply as general guidelines:

• Account and Identity Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, as required under PAGCOR's licensing conditions and the Anti-Money Laundering Act.
• Financial Transaction Data: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLA record-keeping requirements.
• Gaming Activity Data: Retained for a minimum of two (2) years from the date of the gaming session, subject to longer retention where required for dispute resolution or regulatory reporting.
• Technical and Log Data: Retained for up to twelve (12) months, except where specific log records are required for an active security investigation or legal proceeding.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, to demonstrate compliance with consent requirements.

Data that has reached the end of its applicable retention period is securely deleted from jlhp's systems or anonymized in a manner that makes re-identification reasonably impossible. Anonymized data may be retained indefinitely for aggregate analytics purposes.

jlhp implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Encryption: All data transmitted between your device and jlhp's servers is encrypted using Transport Layer Security (TLS 1.2 or higher). The Platform enforces HTTPS for all connections.
• Data Encryption at Rest: Personal data stored in jlhp's databases is encrypted using AES-256 encryption. Encryption keys are managed through a dedicated key management system with access logging.
• Access Controls: Access to systems containing personal data is restricted on a role-based, need-to-know basis. All administrative access requires multi-factor authentication and is logged for audit purposes.
• Vulnerability Management: jlhp conducts regular security assessments and penetration tests of its platform infrastructure. Critical and high-severity vulnerabilities are remediated within defined timeframes.
• Incident Response: jlhp maintains a documented personal data breach response procedure. In the event of a breach affecting your personal data, jlhp will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay where required by law.

While jlhp implements robust security measures, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your jlhp login credentials and for using secure, private networks when accessing your account.

jlhp uses cookies and similar technologies (local storage, session tokens) on its Platform to support essential functions and improve user experience. The categories of cookies used are:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, security cookies, and cookies that remember your login state. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred game view, and responsible gaming settings. Disabling these may affect your experience but will not prevent access.
• Analytics Cookies: Used to collect aggregated, anonymized data on how users interact with the Platform — which games are accessed most frequently, average session durations, and error rates. This data helps jlhp improve the Platform. Analytics data is not linked to your identity.
• Security and Fraud Detection Cookies: Support jlhp's fraud prevention systems by establishing session continuity and detecting anomalous access patterns consistent with credential theft or bot activity.

jlhp does not use third-party behavioral advertising cookies or tracking pixels that share your data with external advertising networks. You may manage cookie preferences through your browser settings, though disabling strictly necessary cookies will prevent Platform access.

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by jlhp. To exercise any of these rights, contact jlhp's Data Protection Officer at [email protected] with the subject line "DATA SUBJECT REQUEST".

The jlhp Platform is strictly intended for users who are 21 years of age or older, consistent with the minimum gambling age under Philippine law. jlhp does not knowingly collect personal data from persons under 21 years of age. The KYC verification process is designed to prevent underage registration.

If jlhp becomes aware that personal data has been collected from a person under 21, the associated account will be immediately closed, all personal data collected will be deleted to the extent not required to be retained for regulatory compliance purposes, and the matter will be reported to PAGCOR as required by jlhp's licensing conditions.

If you are a parent or guardian and believe that a person under 21 has registered an account with jlhp using false age information, please contact jlhp's support team immediately at [email protected] with the subject line "UNDERAGE ACCOUNT REPORT" for expedited handling.

Certain game providers, infrastructure partners, and identity verification services engaged by jlhp may process or store personal data on servers located outside the Philippines. Where personal data is transferred to a third country, jlhp ensures that such transfers are conducted in accordance with the Data Privacy Act's requirements for cross-border data flows, including:

• Requiring the recipient to implement data protection standards equivalent to those mandated by Philippine law through contractual data processing agreements.
• Transferring only the minimum data necessary for the specific service being provided.
• Ensuring that recipients are subject to binding corporate rules or other approved transfer mechanisms recognized by the National Privacy Commission.

Details of the countries to which personal data may be transferred are available upon request from jlhp's Data Protection Officer.

jlhp reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or jlhp's data processing practices. Material changes — defined as changes that significantly affect how your personal data is used or your rights as a data subject — will be communicated to you via email to your registered address at least fourteen (14) days before the changes take effect.

Minor or administrative changes (such as corrections to contact details or clarifications that do not alter the substance of the Policy) may be made without advance notice. The "Last Updated" date at the top of this Policy will be revised whenever any change is made. The current version of this Policy is always available at jlhp.one/privacy-policy.

Your continued use of the Platform after the effective date of a Policy amendment constitutes your acceptance of the amended Policy. If you do not accept a material amendment, you must stop using the Platform and may request account closure in accordance with jlhp's Terms and Conditions.

For all privacy-related inquiries, requests to exercise your data subject rights, or concerns about jlhp's personal data processing practices, please contact:

• Data Protection Officer, jlhp
• Email: [email protected] — Subject Line: "DATA PRIVACY INQUIRY"
• Support Hours: 24 hours a day, 7 days a week
• Response Time: Within 30 days for data subject requests; within 48 hours for urgent privacy matters during Philippine business hours

If you are not satisfied with jlhp's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the independent regulatory body responsible for enforcing the Data Privacy Act of 2012. Information about filing an NPC complaint is available through the NPC's official government channels.