Privacy Policy – jlhot Casino

1. Who We Are

1.1 jlhot Casino operates the online gambling platform accessible at jlhot.club, offering casino games, live dealer tables, sports betting, bingo, sabong, and related services to players in the Philippines.

1.2 jlhot operates under applicable Philippine gaming regulations and takes its obligations as a data controller under the Data Privacy Act of 2012 (Republic Act No. 10173) seriously. We have appointed a Data Protection Officer (DPO) who can be contacted as described in Section 15.

1.3 This Privacy Policy applies to all personal data collected through the jlhot.club website, any associated mobile-optimized interface, customer support channels, and all related communications between jlhot and its registered players.

2. Personal Data We Collect

2.1 jlhot collects the following categories of personal data about you:

2.2 jlhot does not collect special categories of sensitive personal data (such as health information, political opinions, religious beliefs, or biometric data) except where strictly required for responsible gaming assessments or as mandated by Philippine regulatory authorities.

3. How We Collect Your Data

3.1 Directly from You. Most personal data is collected directly from you when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or interact with promotional features.

3.2 Automatically. When you use the jlhot Platform, technical data such as IP address, device identifiers, session data, and cookies are collected automatically through standard internet technologies. See Section 8 for full cookie information.

3.3 From Third Parties. jlhot may receive data about you from third-party service providers including payment processors (GCash, Maya, BPI, BDO, Metrobank, GrabPay), identity verification services, fraud prevention agencies, and game providers. All such third parties are contractually bound to share data only in accordance with applicable law.

3.4 From PAGCOR and Other Regulatory Authorities. jlhot may be required to share or receive player information with or from PAGCOR or other Philippine government authorities in connection with anti-money laundering obligations, fraud investigations, or regulatory audits.

4. How We Use Your Personal Data

4.1 jlhot uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your jlhot player account, verify your identity, process login requests, and manage account security.
• Payment Processing: To process deposits and withdrawals via GCash, Maya, and other supported Philippine payment methods; to detect and prevent fraudulent transactions.
• Regulatory Compliance: To fulfil obligations under PAGCOR regulations, the Anti-Money Laundering Act (RA 9160), the Data Privacy Act (RA 10173), and other applicable Philippine laws. This includes mandatory record-keeping and reporting to the Anti-Money Laundering Council (AMLC).
• Responsible Gaming: To monitor gaming behaviour and identify patterns that may indicate problem gambling; to administer deposit limits, cooling-off periods, and self-exclusion requests in accordance with the jlhot Responsible Gaming policy.
• Customer Support: To respond to your enquiries, resolve disputes, and maintain records of communications for quality assurance purposes.
• Platform Improvement: To analyse aggregate usage patterns, improve game offerings, and optimise the jlhot user experience for Filipino players.
• Marketing Communications: To send promotional offers, bonus notifications, and platform news — but only where you have opted in to receive such communications and in accordance with Section 4.2 below.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, bonus abuse, and other prohibited conduct.

4.2 Marketing. jlhot will only send you promotional communications where you have provided explicit consent during registration or subsequently opted in via account settings. You may withdraw consent for marketing communications at any time by updating your notification preferences in account settings or by contacting support.

5. Legal Basis for Processing

5.1 Under the Data Privacy Act of 2012, jlhot relies on the following legal bases for processing your personal data:

• Contractual Necessity: Processing necessary for the performance of your player account agreement with jlhot (account registration, payment processing, game access).
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and tax obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, and service improvement where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and certain cookie categories where your explicit consent has been obtained.

6. Sharing Your Personal Data

6.1 jlhot does not sell your personal data to any third party under any circumstances.

6.2 jlhot shares your personal data only with the following categories of recipients, and only to the extent necessary:

• Payment Processors: GCash (G-Xchange Inc.), Maya (PayMaya Philippines), BPI, BDO, Metrobank, and other payment service providers necessary to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification services used to verify your identity and age in accordance with PAGCOR requirements.
• Game Providers: Software providers such as Jili, PG Soft, and Pragmatic Play receive limited technical data necessary for game delivery; they do not receive full player identity data.
• Fraud Prevention and Security: Third-party fraud detection and cybersecurity service providers engaged to protect the jlhot platform and its players.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies as required by law.
• Professional Advisers: Legal, accounting, and audit firms under strict confidentiality obligations where necessary for business operations.

6.3 All third-party service providers are required by contract to process your personal data only on jlhot's instructions, to maintain appropriate security standards, and to comply with applicable Philippine data protection law.

7. Data Retention

7.1 jlhot retains your personal data for as long as your player account remains active and for a minimum of five (5) years following account closure. This retention period is required by PAGCOR regulations and the Anti-Money Laundering Act.

7.2 Specific retention periods applicable to categories of data:

• Identity and KYC documents: Minimum 5 years from account closure.
• Financial transaction records: Minimum 5 years from the date of transaction.
• Gaming history: Minimum 3 years from the date of each session.
• Customer support communications: 3 years from date of communication.
• Marketing consent records: Until consent is withdrawn, then 1 year thereafter.

7.3 Upon expiry of applicable retention periods, jlhot will securely delete or anonymise your personal data in accordance with its data deletion procedures.

8. Cookies & Tracking Technologies

8.1 The jlhot Platform uses cookies and similar tracking technologies to deliver a functional, personalised, and secure experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for core platform functionality including authentication, session management, and security. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming limits. These improve your experience and can be disabled via browser settings.
• Analytical Cookies: Collect anonymised aggregate data about how players use the jlhot Platform, used to identify improvements. No personally identifiable information is collected through analytical cookies.
• Marketing Cookies: Used only with your consent to personalise promotional offers and track the effectiveness of marketing activities. These can be managed via account settings.

8.2 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the jlhot Platform.

9. Your Rights Under the Data Privacy Act

9.1 As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jlhot:

• Right to be Informed: The right to know what personal data jlhot collects, why it is collected, and how it is used — as described in this Policy.
• Right to Access: The right to request a copy of the personal data jlhot holds about you, free of charge, subject to one request per calendar year.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held about you.
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data where jlhot no longer has a legal basis for retaining it. Note that regulatory retention obligations under Philippine law may limit this right.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe jlhot has violated your data privacy rights.

9.2 To exercise any of the above rights, please contact jlhot's Data Protection Officer as described in Section 15. jlhot will respond to all verified data subject requests within fifteen (15) business days.

10. Data Security

10.1 jlhot implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• 256-bit SSL/TLS encryption for all data transmission between your device and jlhot servers.
• Encrypted storage of all personal data and financial information at rest.
• Role-based access controls ensuring that jlhot staff can only access personal data necessary for their specific job function.
• Regular security assessments, penetration testing, and vulnerability management.
• Multi-factor authentication for all internal systems and administrative access.
• Incident response procedures for detecting, investigating, and reporting data breaches in accordance with NPC requirements.

10.2 Data Breach Notification. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jlhot will notify the National Privacy Commission within 72 hours of becoming aware of the breach and will inform affected players without undue delay.

10.3 While jlhot takes every reasonable precaution to secure your personal data, no internet transmission or electronic storage system is completely secure. You are encouraged to use strong, unique passwords and to enable two-factor authentication on your jlhot account.

11. International Data Transfers

11.1 Where jlhot's service providers or game providers are located outside the Philippines, your personal data may be transferred to and processed in other jurisdictions. jlhot ensures that all international data transfers are subject to appropriate safeguards as required by the Data Privacy Act of 2012 and the National Privacy Commission's guidelines on cross-border data transfers.

11.2 Such safeguards include contractual data processing agreements that require recipient entities to provide a level of data protection equivalent to the standards required under Philippine law.

12. Third-Party Services and Links

12.1 The jlhot Platform does not contain links to external third-party websites. All content and services are delivered within the jlhot.club domain.

12.2 Game software delivered through the jlhot Platform is provided by third-party game studios under contractual arrangements with jlhot. These providers operate under their own privacy and security standards, and jlhot requires all game providers to meet minimum data protection standards as a condition of their integration on the Platform.

13. Children's Privacy

13.1 The jlhot Platform is strictly intended for adults aged twenty-one (21) years and above, in accordance with PAGCOR's online gambling regulations. jlhot does not knowingly collect or process personal data from persons under the age of 21.

13.2 If jlhot discovers that personal data has been collected from an individual under 21 years of age, such data will be deleted promptly and the associated account closed. If you believe a person under 21 has registered on jlhot, please contact us immediately at [email protected].

14. Changes to This Privacy Policy

14.1 jlhot reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or the services we provide. The "Effective Date" at the top of this Policy indicates when the current version came into force.

14.2 Where changes are material, jlhot will provide notice to registered players via the email address registered on their account or via a prominent notice displayed on the Platform for a period of at least 14 days prior to the changes taking effect.

14.3 Your continued use of the jlhot Platform following the effective date of any amended Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you must cease using the Platform and may close your account in accordance with the Terms & Conditions.

15. Contact Us & Data Protection Officer

15.1 For any questions, concerns, or requests relating to this Privacy Policy or your personal data rights, please contact jlhot Casino's Data Protection Officer:

Please include your full name, registered mobile number or email address, and a clear description of your request when contacting the DPO. jlhot may request additional verification before processing data subject requests to protect against unauthorised disclosure.