89jl Privacy Policy

1 Introduction

89jl ("we," "us," "our," "89jl") is committed to protecting the privacy and personal data of all players and visitors who use the 89jl online gaming platform available at https://89jl.asia ("Platform"). This Privacy Policy is a binding legal document that governs the collection, use, processing, and disclosure of personal data in connection with your use of 89jl.

This Policy applies to all users of the 89jl Platform, including players registered in Metro Manila, Cebu, Davao, Quezon City, Makati, and across the Philippines. This Policy is drafted in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC) of the Philippines.

By accessing or using 89jl, you represent that you are at least 21 years of age, the legal minimum age required under PAGCOR regulations and the laws of the Philippines for participation in online casino-style gaming.

2 Data Controller

89jl acts as the data controller in respect of the personal data collected through the Platform. As data controller, 89jl determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is lawful, fair, and transparent.

89jl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. The DPO may be contacted through the details provided in Section 14 of this Policy.

3 Personal Data We Collect

89jl collects personal data through various means, including when you register an account, make a deposit or withdrawal, use our games, contact customer support, or interact with the Platform in any other way. The categories of personal data we may collect include:

3.1 Identity and Contact Data:

• Full legal name;
• Date of birth (for age verification purposes, 21+ requirement);
• Philippine mobile number;
• Email address (where provided);
• Government-issued identification (for KYC/AML verification, such as PhilSys ID, driver's license, or passport).

3.2 Financial Data:

• GCash account number or Maya account details linked to your 89jl wallet;
• Bank account details (BPI, BDO, Metrobank) where used for transactions;
• Transaction history including deposits, withdrawals, and gaming activity;
• Cryptocurrency wallet addresses where applicable (USDT transactions).

3.3 Technical and Usage Data:

• IP address and device identifiers;
• Browser type and version;
• Operating system and device type (mobile, tablet, desktop);
• Pages visited, game sessions accessed, and time spent on the Platform;
• Geolocation data (general region level, for regulatory compliance);
• Login timestamps and session duration data.

3.4 Communications Data:

• Customer support chat logs and records;
• Any correspondence you send to 89jl via email or support channels;
• Feedback, survey responses, and promotional engagement records.

4 How We Use Your Personal Data

89jl processes your personal data for the following specific purposes:

• Account Management: To create, maintain, and manage your 89jl player account, including authentication and security;
• Service Delivery: To provide access to games, process deposits and withdrawals via GCash, Maya, BDO, BPI, and other payment methods, and deliver the gaming experience you expect;
• Identity Verification (KYC): To verify your age (21+) and identity in compliance with PAGCOR-related requirements and Philippine AML laws;
• Financial Processing: To process, record, and reconcile all financial transactions on your account, including calculating and paying out winnings;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent, abusive, or unauthorized activity on the Platform;
• Regulatory Compliance: To comply with applicable laws, regulations, court orders, and requests from PAGCOR or other Philippine regulatory authorities;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Responsible Gaming: To monitor gaming patterns and implement responsible gaming measures, including enforcing deposit limits and self-exclusion requests;
• Platform Improvement: To analyse usage patterns and improve the functionality, performance, and user experience of 89jl;
• Communications: To send you account notifications, transactional messages, promotional offers (where you have consented), and important policy updates.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act, 89jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 89jl (i.e., to operate your gaming account and deliver our services);
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, PAGCOR-related compliance requirements, and data retention obligations;
• Legitimate Interests: Processing is necessary for 89jl's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights;
• Consent: Where processing is based on your consent (such as for marketing communications), you may withdraw that consent at any time by contacting our support team.

6 Data Sharing & Disclosure

89jl does not sell, rent, or trade your personal data to unaffiliated third parties for marketing purposes. We may share your personal data with the following categories of recipients strictly for the purposes described in this Policy:

• Payment Processors: GCash (GXI / Globe Fintech Innovations Inc.), Maya (Voyager Innovations / PayMaya Philippines Inc.), partner banks (BPI, BDO, Metrobank), and other payment service providers, for the purpose of processing deposits and withdrawals on your account;
• Game Providers: Third-party game studios and live casino operators whose games are made available on the 89jl platform, who may receive limited technical data to deliver their game services;
• KYC/Identity Verification Services: Third-party identity verification and AML screening providers used to verify your identity and comply with Philippine regulatory obligations;
• IT and Cloud Service Providers: Hosting, storage, cybersecurity, and analytics service providers who process data on our behalf under contractual obligations consistent with this Policy;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, courts, and other Philippine governmental bodies where disclosure is required by law or court order;
• Professional Advisors: Lawyers, auditors, and financial advisors engaged in connection with our business operations, under professional secrecy obligations.

All third parties with whom 89jl shares personal data are required to handle that data in compliance with the Philippine Data Privacy Act and applicable contractual data protection obligations.

7 Cookies & Tracking Technologies

89jl uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session state, and collect analytics data. The categories of cookies used include:

• Strictly Necessary Cookies: Essential for the Platform to function, including session authentication and security tokens. These cannot be disabled;
• Functional Cookies: Remember your preferences and settings, such as language or display options;
• Analytics Cookies: Collect aggregated and anonymised data about how players use the Platform, to improve performance and content;
• Security Cookies: Used to detect and prevent fraud, bot activity, and unauthorized access to accounts.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 89jl Platform. Mobile users on Globe, Smart, or DITO networks accessing 89jl via a browser may still be subject to cookies during their session.

8 Data Retention

89jl retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following considerations:

• Account data is retained for the duration of your active account relationship with 89jl and for a minimum period thereafter as required by Philippine law, including AML record-keeping obligations;
• Transaction records are retained for a minimum of five (5) years from the date of the transaction, in compliance with applicable Philippine financial regulations;
• KYC and identity verification records are retained for the period required under Philippine AML law;
• Customer support communications are retained for a minimum of two (2) years;
• Where data is retained solely for legal compliance purposes, access is restricted to personnel with a specific need to access such records.

When personal data is no longer required for any of the above purposes, it is securely deleted or anonymised in accordance with our internal data retention and deletion procedures.

9 Data Security

89jl employs appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• TLS/SSL encryption for all data in transit between your device and 89jl's servers;
• Encryption of sensitive data at rest, including financial information and government identification records;
• Access controls ensuring that personal data is accessible only to authorised 89jl personnel with a legitimate need;
• Regular security audits, penetration testing, and vulnerability assessments;
• Multi-factor authentication for internal systems handling player data;
• Incident response procedures for detecting, reporting, and responding to personal data breaches in accordance with NPC notification requirements.

Notwithstanding the above, no method of electronic transmission or storage is 100% secure. Players are responsible for maintaining the security of their own 89jl account credentials and for promptly notifying 89jl if they suspect unauthorised access to their account.

10 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 89jl:

To exercise any of these rights, please contact 89jl's Data Protection Officer using the contact details in Section 14. We will respond to all data subject requests within the timeframes required by the Philippine Data Privacy Act and NPC guidelines. We may need to verify your identity before processing your request.

If you believe your data privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

11 Children's Privacy

The 89jl platform is strictly for individuals aged 21 years and above. 89jl does not knowingly collect, process, or retain personal data of persons under the age of 21. In compliance with PAGCOR regulations, all players are required to confirm their age upon registration and may be required to submit proof of age.

If 89jl becomes aware that it has inadvertently collected personal data from an individual under the age of 21, we will promptly delete such data and close the associated account. If you are a parent or guardian and believe your child has accessed or registered on 89jl, please contact us immediately at [email protected] (plain text only).

12 International Data Transfers

In the course of operating the 89jl Platform, your personal data may be processed or stored on servers located outside the Philippines, particularly in connection with third-party cloud hosting, game providers, and technology service providers. Where such transfers occur, 89jl ensures that appropriate safeguards are in place to protect your personal data, consistent with the requirements of the Philippine Data Privacy Act and the data transfer mechanisms recognised by the National Privacy Commission.

Such safeguards include contractual data processing agreements requiring recipient parties to maintain data protection standards equivalent to those required under Philippine law.

13 Updates to This Privacy Policy

89jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. The revised Policy will be published on this page with an updated effective date. Where changes are material, we will endeavour to provide reasonable notice to registered players via in-platform notification or to the contact details on file.

Your continued use of the 89jl Platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how 89jl protects your personal data.

14 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 89jl, please contact us through the following channels:

• Data Protection Officer (DPO) Email: [email protected] (plain text only — not a clickable link)
• Subject Line: Please include "Privacy / DPO Request" in the subject line of your communication for expedited handling
• Live Chat: 24/7 support is available through the in-platform live chat feature for general account and privacy inquiries
• Response Time: Privacy-related requests are handled within 15 business days; urgent security concerns within 72 hours

For complaints about 89jl's data privacy practices that are not resolved to your satisfaction, you may file a complaint with the National Privacy Commission of the Philippines.