Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") describes how jliss ("jliss," "we," "us," or "our") collects, processes, stores, and protects the personal information of individuals ("you," "Player," or "User") who access or use the jliss online gaming platform at jliss.app and its associated services (collectively, the "Platform").

This Policy is issued in compliance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). By registering an account or using the jliss 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.

This Policy should be read alongside the jliss Terms & Conditions, which govern your use of the Platform more broadly.

2. Personal Data We Collect

jliss collects personal data through several channels: directly from you during registration and account use, automatically through your interaction with the Platform, and from third-party sources where permitted by law. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., Philippine passport number, SSS number, PhilSys National ID number, driver's license number).
• Contact Data: Email address, mobile phone number, and residential address (including barangay, city/municipality, province, and postal code).
• Account Data: Username, password (stored in hashed form), account preferences, and communication preferences.
• Financial Data: GCash account details, PayMaya account details, bank account information (BPI, BDO, Metrobank), and transaction history including deposits, withdrawals, and wager records.
• Verification Documents: Copies of government-issued IDs, proof of address documents, and selfie photographs submitted for KYC verification purposes.
• Communications: Records of your interactions with jliss customer support, including live chat transcripts and email correspondence.

2.2 Data Collected Automatically

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and mobile network information.
• Usage Data: Pages visited, games played, session duration, betting patterns, login timestamps, and navigation paths within the Platform.
• Location Data: General geographic location derived from your IP address. jliss does not collect precise GPS location data.
• Cookie Data: Information collected through cookies and similar tracking technologies as described in Section 6 of this Policy.

2.3 Data from Third Parties

• Payment Processors: Transaction confirmation data from GCash, PayMaya, and banking partners to verify deposits and withdrawals.
• Identity Verification Services: Results from third-party KYC and AML screening services used to verify your identity and comply with regulatory obligations.
• Fraud Prevention Services: Risk signals and fraud indicators from third-party security providers used to protect the integrity of the Platform.

3. How We Use Your Personal Data

jliss uses your personal data only for legitimate, specified purposes. The table below summarises the primary purposes for which we process your data and the corresponding legal basis for each:

jliss will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis for the new processing activity.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, jliss processes your personal data on the following legal bases:

• Consent: Where you have given clear, informed, and freely given consent to the processing of your personal data for a specific purpose, such as receiving marketing communications from jliss.
• Contract Performance: Where processing is necessary to perform the contract between you and jliss — specifically, to operate your account, process your transactions, and deliver the gaming services you have requested.
• Legal Obligation: Where processing is required to comply with applicable Philippine laws and regulations, including the Data Privacy Act, Anti-Money Laundering Act, and gaming regulations administered by PAGCOR.
• Legitimate Interest: Where processing is necessary for the legitimate interests of jliss or a third party, provided those interests are not overridden by your rights and interests. This includes fraud prevention, platform security, and service improvement activities.

5. Data Sharing & Disclosure

jliss does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data only in the following limited circumstances:

• Payment Processors: We share necessary financial data with GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners solely to process your deposits and withdrawals.
• Identity Verification Providers: We share identity documents and personal details with licensed KYC and AML screening service providers to fulfil our regulatory verification obligations.
• Game Content Providers: Game providers who supply slot, live dealer, and other game content to the jliss Platform may receive anonymised session data necessary to deliver their services.
• Regulatory Authorities: We are required by law to disclose certain player data to PAGCOR and other Philippine regulatory bodies upon lawful request, including transaction records relevant to AML investigations.
• Law Enforcement: We will disclose personal data to law enforcement agencies, courts, or government bodies where required by a valid legal order, warrant, or subpoena issued under Philippine law.
• Fraud Prevention Networks: We may share fraud risk signals with industry fraud prevention services to protect the Platform and other players from fraudulent activity.
• Corporate Transactions: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party service providers who process personal data on behalf of jliss are bound by data processing agreements that require them to handle your data securely, use it only for the specified purpose, and comply with applicable data protection laws.

6. Cookies & Tracking Technologies

The jliss Platform uses cookies and similar tracking technologies to deliver a functional, personalised, and secure experience. A cookie is a small text file placed on your device when you visit the Platform.

6.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming limits you have set.
• Analytics Cookies: Collect anonymised data about how players use the Platform — which pages are visited most, where players encounter errors, and how navigation flows are used. This data helps us improve the jliss experience.
• Performance Cookies: Monitor Platform performance, load times, and technical errors to ensure a smooth gaming experience across devices.

6.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling certain cookies may affect the functionality of the jliss Platform, including your ability to stay logged in or access certain features. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate securely.

7. Data Retention

jliss retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements under Philippine law.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act of 2001 and its amendments.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory investigation or legal proceeding.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, whichever occurs first.
• Technical and Usage Logs: Retained for up to twelve (12) months for security and fraud prevention purposes, after which they are anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with jliss data disposal procedures.

8. Data Security

jliss implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security framework includes:

• Encryption: All data transmitted between your device and the jliss Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including financial information and identity documents, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. jliss staff are granted access only to the data necessary to perform their specific job functions, and all access is logged and audited.
• Password Security: Account passwords are stored using one-way cryptographic hashing. jliss staff cannot view your password in plain text.
• Two-Factor Authentication: jliss offers two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorised access.
• Penetration Testing: The Platform undergoes regular security assessments and penetration testing by independent security professionals to identify and remediate vulnerabilities.
• Incident Response: jliss maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected players in accordance with the Data Privacy Act of 2012.

9. Your Data Privacy Rights

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

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfils that obligation.
• Right of Access: You have the right to request a copy of the personal data that jliss holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most account information directly through your jliss account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations under Philippine AML and gaming regulations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interest, subject to jliss demonstrating compelling legitimate grounds.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact the jliss Data Privacy Officer via the support email listed in Section 13. We will respond to all verified requests within fifteen (15) business days, in accordance with NPC guidelines.

10. Children's Privacy

The jliss Platform is strictly intended for individuals who are at least twenty-one (21) years of age. We do not knowingly collect personal data from individuals under the age of 21. Real-money gambling is prohibited for minors under Philippine law, and jliss enforces this restriction through mandatory age verification during the registration and KYC process.

If jliss becomes aware that personal data has been collected from an individual under the age of 21 without verifiable parental consent, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact our support team immediately.

11. International Data Transfers

jliss primarily processes and stores personal data within the Philippines. However, some of our third-party service providers — including game content providers, cloud infrastructure partners, and fraud prevention services — may process data in other jurisdictions.

Where personal data is transferred outside the Philippines, jliss ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual clauses approved by the National Privacy Commission, adequacy decisions, or binding corporate rules, as applicable.

12. Changes to This Privacy Policy

jliss reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. The date of the most recent revision is always displayed at the top of this page.

Where changes are material — meaning they significantly affect how we process your personal data or your rights — jliss will notify you by email or through a prominent notice on the Platform at least fourteen (14) days before the changes take effect. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

13. Contact & Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jliss, please contact our Data Privacy Officer:

Email: [email protected]

Our support team is available 24 hours a day, 7 days a week via live chat on the Platform. For formal data privacy requests — including access, rectification, erasure, or portability requests — please contact us by email with the subject line "Data Privacy Request" and include your registered account email address and a description of your request.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been adequately addressed by jliss.