jlber Casino – Privacy Policy

1.1 This Privacy Policy ("Policy") is issued by jlber ("jlber," "we," "us," "our") and applies to all personal data processed in connection with your use of the jlber online casino and sports betting platform at jlber.club ("Platform"), including account registration, gameplay, financial transactions, customer support interactions, and marketing communications.

1.2 jlber is committed to protecting your personal data and complying with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA) of the Philippines, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

1.3 By registering an account, making a deposit, or otherwise using the jlber 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, please discontinue use of the Platform immediately.

2.1 For purposes of the Data Privacy Act of 2012, jlber operates as the personal information controller ("PIC") with respect to the personal data it collects and processes in connection with the Platform.

2.2 jlber has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection legislation. The DPO may be contacted via the details provided in Section 15.

jlber collects the following categories of personal data, depending on the nature of your interaction with the Platform:

3.1 Sensitive Personal Information. Where jlber collects sensitive personal information as defined under the DPA (including government-issued ID details for KYC purposes), such data is processed only to the extent strictly necessary for identity verification and regulatory compliance, and is subject to enhanced security controls.

jlber collects personal data through the following means:

• Direct submission: Information you provide when registering an account, updating your profile, completing KYC, making deposits or withdrawals, or contacting support;
• Automated collection: Technical data collected automatically when you access the Platform, including via cookies, log files, and similar tracking technologies (see Section 7);
• Third-party sources: Identity verification data from KYC service providers, fraud detection services, and payment processors such as GCash and PayMaya;
• Regulatory disclosures: Data shared by PAGCOR or other regulatory bodies in connection with licensing obligations or investigations.

jlber processes your personal data for the following purposes and on the following legal bases under the DPA:

• Account management and service delivery — necessary for performance of our contract with you as a registered jlber player;
• Identity and age verification (KYC) — necessary for compliance with PAGCOR licensing obligations and the 21+ age requirement;
• Financial transaction processing — necessary for performance of the contract and compliance with anti-money laundering (AML) regulations;
• Fraud prevention and security monitoring — legitimate interest in protecting the Platform, its players, and its financial integrity;
• Regulatory compliance and reporting — legal obligation under PAGCOR regulations and Philippine AML/CTF laws;
• Responsible gaming monitoring — legitimate interest in identifying and protecting at-risk players;
• Marketing communications — consent, which you may withdraw at any time through your account settings;
• Platform improvement and analytics — legitimate interest in maintaining and improving the jlber service.

6.1 jlber does not sell your personal data to third parties. We may share your personal data only in the circumstances described below:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other financial institutions — solely to process your deposits and withdrawals;
• KYC and fraud prevention providers: Third-party identity verification services used to confirm your identity and detect fraudulent activity;
• Game providers: JILI, Pragmatic Play, PG Soft, and other game software providers — limited technical data necessary for game delivery and integrity monitoring;
• Regulatory authorities: PAGCOR and other Philippine regulatory or law enforcement bodies where disclosure is required by law or regulation;
• IT and hosting service providers: Data centre and cloud service providers who process data on jlber's behalf under strict data processing agreements;
• Professional advisors: Lawyers, auditors, and consultants, subject to professional confidentiality obligations.

6.2 All third-party service providers who process personal data on behalf of jlber are required to comply with the DPA and to implement appropriate technical and organisational security measures.

7.1 jlber uses cookies and similar tracking technologies to operate the Platform, maintain your login session, prevent fraud, and analyse Platform usage. The categories of cookies used are:

• Strictly necessary cookies: Required for the Platform to function — login sessions, security tokens, and fraud prevention. These cannot be disabled;
• Functional cookies: Remember your preferences such as language settings and display options;
• Analytics cookies: Aggregate, anonymised data on how players use the Platform, used to improve features and performance;
• Marketing cookies: Track engagement with promotional campaigns. Used only where you have consented.

7.2 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair Platform functionality including the ability to log in to your jlber account.

8.1 jlber retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. Key retention periods are:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AML/CTF record-keeping requirements;
• Financial transaction records: Retained for five (5) years following each transaction;
• Gaming history: Retained for three (3) years following the last recorded session;
• Customer support records: Retained for two (2) years from the date of the last interaction;
• Marketing data: Retained until you withdraw consent, or for one (1) year of inactivity, whichever is earlier.

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised.

9.1 jlber implements appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or disclosure. These measures include, without limitation:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jlber's servers;
• Encryption of stored sensitive data including financial account details and government ID numbers;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Multi-factor authentication for administrative system access;
• Regular penetration testing and vulnerability assessments;
• Intrusion detection and real-time security monitoring.

9.2 In the event of a personal data breach that is likely to result in harm to affected individuals, jlber will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the DPA.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jlber:

• Right to be informed: To be informed of the data being collected and the purpose of processing before or at the time of collection;
• Right of access: To obtain a copy of the personal data jlber holds about you;
• Right to rectification: To correct inaccurate or incomplete personal data;
• Right to erasure: To request deletion of your personal data where processing is no longer necessary, subject to jlber's legal retention obligations;
• Right to object: To object to processing of your personal data for direct marketing purposes at any time;
• Right to data portability: To receive your personal data in a structured, commonly used format;
• Right to damages: To be indemnified for damages sustained due to inaccurate, incomplete, or unauthorised use of personal data.

To exercise any of the above rights, contact jlber's Data Protection Officer using the details in Section 15. jlber will respond within thirty (30) calendar days. We may request proof of identity before fulfilling a data rights request.

11.1 The jlber Platform is strictly for individuals aged 21 years and above. jlber does not knowingly collect personal data from persons under 21 years of age. If you are a parent or guardian and believe your child has provided personal data to jlber, please contact us immediately using the details in Section 15.

11.2 Upon confirmed receipt of such a report, jlber will promptly delete the relevant personal data and close any account found to belong to a person under the minimum age requirement.

12.1 Some of jlber's service providers, including cloud hosting and game providers, may process your data on servers located outside the Philippines. Where such transfers occur, jlber ensures that appropriate safeguards are in place, including contractual data processing agreements that impose obligations equivalent to those under the Data Privacy Act of 2012.

12.2 jlber will not transfer personal data to jurisdictions that do not offer an adequate level of data protection without implementing appropriate contractual or technical safeguards.

The jlber Platform does not contain links to third-party websites. In the event that any third-party service accessible through the Platform maintains its own privacy practices, jlber is not responsible for those practices. You are encouraged to review the privacy policies of any third-party services you access independently of the jlber Platform.

14.1 jlber reserves the right to amend this Privacy Policy at any time. Material changes will be communicated by a notice on the Platform homepage or by email to your registered address at least fourteen (14) days before the amended Policy takes effect.

14.2 The date of the most recent revision is displayed at the top of this page. Your continued use of the jlber Platform after the effective date of any amendment constitutes acceptance of the revised Policy.

15.1 For questions, data rights requests, or complaints regarding jlber's data processing practices, you may contact our Data Protection Officer through the live chat feature available on the Platform 24/7, or by email at [email protected].

15.2 If you are not satisfied with jlber's response to a complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.