jlbe Casino Privacy Policy – How We Protect Your Data

1. Introduction & Scope

This Privacy Policy ("Policy") is published by jlbe ("jlbe," "we," "us," or "the Company") and applies to all personal data collected and processed by jlbe in connection with your use of the jlbe Platform at jlbe.org, including all associated gaming services, mobile-optimised interfaces, and communications channels.

jlbe operates under a PAGCOR license and is subject to 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. This Policy is drafted in compliance with those requirements and reflects our genuine commitment to handling your personal information with care and transparency.

By registering an account with jlbe or continuing to use the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with how jlbe processes personal data as described herein, please discontinue use of the Platform and contact us to arrange account closure.

2. Personal Data We Collect

jlbe collects the following categories of personal data from members and Platform visitors:

jlbe does not collect special categories of sensitive personal data (as defined under the Data Privacy Act) such as health, biometric, or political data, except where expressly required for responsible gaming assessments or KYC purposes and with your explicit consent.

3. How We Collect Your Data

jlbe collects personal data through the following means:

• Direct collection: Information you provide when registering a jlbe account, completing KYC verification, making deposits or withdrawals, contacting our support team, or updating your account profile;
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, and server logs when you access the jlbe Platform;
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment confirmation data from GCash, PayMaya, and banking partners;
• Regulatory sources: Data provided to or received from PAGCOR in the course of our licensed operations, as required by applicable gaming regulations.

4. Purposes & Legal Bases for Processing

jlbe processes your personal data for the following purposes, each grounded in a lawful basis under the Data Privacy Act of 2012:

• Account registration and operation — necessary for the performance of our contract with you as a jlbe member;
• Identity verification and KYC compliance — necessary for compliance with PAGCOR regulations and Philippine AML law (Republic Act No. 9160, as amended);
• Payment processing — necessary for the performance of our contract, enabling deposits and withdrawals in Philippine Peso;
• Fraud prevention and security — legitimate interest in protecting jlbe members and the integrity of the Platform;
• Responsible gaming monitoring — legitimate interest and regulatory obligation to identify and support members at risk of gambling-related harm;
• Customer support — necessary for the performance of our contract and legitimate interest in maintaining service quality;
• Marketing communications — based on your consent; you may withdraw consent at any time through your jlbe account settings;
• Legal and regulatory compliance — necessary for compliance with applicable Philippine laws, PAGCOR directives, and court orders.

5. Disclosure of Personal Data

jlbe does not sell, rent, or trade your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• PAGCOR and other regulators: As required by our gaming license and applicable Philippine law;
• KYC and identity verification providers: To fulfil our regulatory obligation to verify member identities;
• Payment processors: GCash, PayMaya, and banking partners (BPI, BDO, Metrobank) to process transactions in PHP;
• Fraud prevention and AML screening services: To protect the Platform and comply with anti-money laundering obligations;
• IT and cloud infrastructure providers: Who process data on our behalf under data processing agreements that require them to maintain confidentiality and security standards equivalent to those applied by jlbe;
• Law enforcement and government authorities: Where required by law, court order, or where jlbe reasonably believes disclosure is necessary to prevent fraud, illegal activity, or a threat to safety.

All third-party service providers engaged by jlbe are required to process your data only on jlbe's instructions and are prohibited from using your personal data for their own independent purposes.

6. International Data Transfers

Some of jlbe's service providers are located outside the Philippines. Where personal data is transferred to a country that the NPC has not recognised as providing adequate data protection, jlbe ensures that appropriate safeguards are in place — such as contractual clauses approved by the NPC — to maintain the level of protection required by the Data Privacy Act of 2012.

You may request further information about the safeguards applied to international data transfers by contacting jlbe's Data Privacy Officer at the address provided in Section 13.

7. Data Retention

jlbe retains your personal data for as long as your account is active and for such further period as is required to fulfil the purposes described in this Policy, comply with legal obligations, or resolve disputes. Specific retention periods are as follows:

• Account and KYC records: retained for a minimum of five (5) years following account closure, as required by PAGCOR and AML regulations;
• Transaction and gaming history: retained for a minimum of five (5) years following the date of the relevant transaction;
• Support communications: retained for three (3) years from the date of the last interaction;
• Marketing preference records: retained until you withdraw consent or close your jlbe account, whichever is earlier.

When data is no longer required for any lawful purpose, jlbe will securely delete or anonymise it in accordance with our data disposal procedures.

8. Cookies & Tracking Technologies

The jlbe Platform uses cookies and similar tracking technologies to operate correctly, remember your preferences, and understand how members interact with the Platform. The cookies used by jlbe fall into the following categories:

• Strictly necessary cookies: Required for the Platform to function — session authentication, security tokens, load balancing. These cannot be disabled;
• Functional cookies: Remember your preferences such as language settings and login state;
• Analytics cookies: Help jlbe understand how members navigate the Platform so we can improve the user experience. Data collected is aggregated and anonymised;
• Marketing cookies: Used only with your consent to deliver relevant jlbe promotions. You may withdraw consent at any time via your browser settings or account preferences.

Most web browsers allow you to control cookies through browser settings. Disabling certain cookies may affect Platform functionality.

9. Security Measures

jlbe implements technical and organisational measures appropriate to the risk level associated with the personal data we process. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the jlbe Platform;
• Encrypted storage of sensitive data, including financial and identity information, at rest;
• Role-based access controls ensuring that jlbe staff can only access personal data necessary for their specific function;
• Multi-factor authentication requirements for administrative access to systems holding personal data;
• Regular security audits and penetration testing by independent third parties;
• Incident response procedures aligned with NPC breach notification requirements.

Despite these measures, no online platform can guarantee absolute security. You are encouraged to use a strong, unique password for your jlbe account, enable biometric login where available, and notify jlbe support immediately if you suspect unauthorised access.

10. Your Rights Under Philippine Data Privacy Law

Under the Data Privacy Act of 2012, jlbe members located in the Philippines have the following rights in relation to their personal data:

• Right to be informed: To know what personal data jlbe holds about you and how it is being processed;
• Right of access: To obtain a copy of the personal data jlbe holds about you;
• Right to rectification: To have inaccurate or incomplete personal data corrected;
• Right to erasure: To request deletion of your personal data, subject to jlbe's legal retention obligations;
• Right to object: To object to processing based on legitimate interests, including direct marketing;
• Right to data portability: To receive your personal data in a structured, commonly used format;
• Right to damages: To claim compensation for damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of personal data.

To exercise any of these rights, contact jlbe's Data Privacy Officer using the details in Section 13. We will respond to valid requests within thirty (30) days. Where a request is complex or numerous, we may extend this period by a further two months and will notify you accordingly.

11. Children's Privacy

The jlbe Platform is strictly for adults. In the Philippines, PAGCOR requires that all online gaming participants be at least 21 years of age. jlbe does not knowingly collect personal data from individuals under the age of 21. If we become aware that a member's account was registered by a person under 21, we will immediately suspend the account, delete the associated personal data to the extent permitted by law, and report the incident to PAGCOR as required.

If you believe a person under 21 has registered a jlbe account, please contact our support team immediately.

12. Changes to This Privacy Policy

jlbe may update this Privacy Policy periodically to reflect changes in our data processing practices, legal requirements, or Platform features. Material changes will be communicated to registered members via the Platform or by email to the address associated with your jlbe account, with a minimum of fourteen (14) days notice before the changes take effect.

The current version of this Policy is always accessible on the jlbe Platform. We recommend reviewing it periodically. Your continued use of the Platform following the effective date of any changes constitutes acceptance of the revised Policy.

13. Contact & Data Privacy Officer

jlbe has appointed a Data Privacy Officer (DPO) as required under the Data Privacy Act of 2012. If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to raise a privacy concern, please contact:

• Data Privacy Officer, jlbe
• Email: [email protected]
• Live Chat: Available 24/7 via the jlbe Platform

If you are not satisfied with jlbe's response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).