92jl Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 92jl ("92jl," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "data subject") who access or use the 92jl online casino platform available at 92jl.app and any associated mobile or web applications (collectively, the "Platform").

92jl is committed to protecting the privacy and security of your personal data. We process personal information in accordance with Republic Act No. 10173, the Philippine Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

By registering an account on the Platform or by continuing to use the 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 with this Policy, please discontinue use of the Platform and contact us to close your account.

This Policy should be read together with the 92jl Terms & Conditions and Responsible Gaming Policy, each of which is incorporated by reference.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the personal information controller responsible for your data is 92jl, operating the Platform at 92jl.app.

92jl has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and with applicable data protection legislation. Contact details for the DPO are provided in Section 14 of this Policy.

3. Personal Data We Collect

92jl collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Identity & Registration Data

• Full legal name
• Date of birth (for age verification — players must be 21 years or older)
• Gender
• Nationality and country of residence
• Government-issued identification number (e.g., Philippine National ID, passport, driver's licence)
• Username and account credentials (password stored in hashed form only)

3.2 Contact Data

• Mobile phone number (Philippine number required for OTP verification)
• Email address
• Residential address (province, city/municipality, barangay, ZIP code)

3.3 Financial & Transaction Data

• GCash or Maya account number (for deposit and withdrawal processing)
• Bank account details (bank name, account number, account name) where bank transfer is used
• Debit card details (card number stored in tokenized form only; full card numbers are never stored by 92jl)
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used
• Account balance and bonus credit history

3.4 Gaming Activity Data

• Game session logs, including games played, wager amounts, win/loss outcomes, and session duration
• Bonus usage and wagering requirement progress
• Responsible gaming tool settings (deposit limits, session reminders, self-exclusion status)

3.5 Technical & Device Data

• IP address and approximate geolocation derived therefrom
• Device type, operating system, and browser type and version
• Unique device identifiers
• Platform access logs, including login timestamps and session duration

3.6 Communications Data

• Records of communications between you and the 92jl customer support team, including live chat transcripts and email correspondence
• Survey responses and feedback submitted through the Platform

4. How We Collect Your Data

92jl collects personal data through the following means:

• Direct Registration: Information you provide when creating your 92jl account, completing KYC verification, or updating your profile.
• Platform Use: Data generated automatically as you navigate and interact with the Platform, including game play, deposits, withdrawals, and customer support interactions.
• Payment Processors: Transaction confirmation data received from GCash, Maya, and Philippine banking partners when you make deposits or withdrawals.
• Automated Technologies: Cookies, web beacons, and similar tracking technologies that collect technical and usage data as described in Section 9.
• Identity Verification Providers: Where required for KYC compliance, data may be verified against third-party identity verification services operating under their own privacy policies.
• Publicly Available Sources: In limited circumstances, 92jl may supplement your data with information from publicly available government or regulatory databases for fraud prevention or AML compliance purposes.

5. Purpose & Legal Basis for Processing

92jl processes your personal data only where a lawful basis exists under the Philippine Data Privacy Act. The table below sets out the primary purposes for which we process your data and the corresponding legal basis:

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.

6. Sharing Your Personal Data

92jl does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

6.1 Payment Service Providers

GCash, Maya, and Philippine banking partners receive the minimum data necessary to process your deposit and withdrawal transactions. These providers operate under their own privacy policies and are bound by applicable Philippine financial regulations.

6.2 Identity Verification & KYC Providers

Third-party KYC and identity verification service providers may process your identity documents and biometric data solely for the purpose of verifying your identity in compliance with PAGCOR licensing requirements and the Anti-Money Laundering Act (AMLA).

6.3 Technology & Infrastructure Providers

Cloud hosting, data storage, and Platform infrastructure providers who process data on our behalf under data processing agreements that require them to maintain appropriate security standards and process data only on 92jl's instructions.

6.4 Game Content Providers

Third-party game studios and live dealer providers may receive anonymized or pseudonymized session data necessary to deliver game content and calculate RTP. These providers do not receive your full identity or financial data.

6.5 Regulatory & Law Enforcement Authorities

92jl may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities where required by law, court order, or regulatory directive.

6.6 Professional Advisers

Legal counsel, auditors, and other professional advisers who are bound by professional confidentiality obligations, where disclosure is necessary for the conduct of their services.

7. Data Retention

92jl 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 and regulation. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Gaming activity logs: Retained for three (3) years from the date of the relevant session.
• Customer support communications: Retained for two (2) years from the date of the last communication.
• Technical and device data: Retained for twelve (12) months from collection, unless required for longer for security or fraud investigation purposes.
• Self-exclusion records: Retained indefinitely to prevent re-registration during an active exclusion period and for a minimum of five (5) years following the expiry of any exclusion.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 92jl's data disposal procedures.

8. Security Measures

92jl implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest, including passwords and payment credentials, is encrypted or hashed using industry-standard algorithms.
• Access Controls: Access to personal data is restricted to authorized 92jl personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Two-Factor Authentication: Account access is protected by OTP-based two-factor authentication sent to your registered Philippine mobile number.
• Penetration Testing: The Platform undergoes regular security assessments and penetration testing by independent security professionals.
• Incident Response: 92jl maintains a data breach response plan. In the event of a personal data breach that poses a real risk to your rights and freedoms, 92jl will notify the National Privacy Commission and affected data subjects within the timeframes prescribed by the DPA.

While 92jl takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying 92jl immediately if you suspect unauthorized access to your account.

9. Cookies & Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the Platform. They allow the Platform to recognize your device, maintain your session, and remember your preferences across visits.

9.2 Types of Cookies Used by 92jl

• Strictly Necessary Cookies: Required for the Platform to function. These include session 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 and responsible gaming tool configurations.
• Analytics Cookies: Collect anonymized data about how players use the Platform to help us identify areas for improvement. 92jl uses privacy-respecting analytics tools that do not share data with third-party advertising networks.

9.3 Managing Cookies

You can control and delete cookies through your browser settings. Please note that disabling strictly necessary cookies will impair the functionality of the Platform and may prevent you from accessing your account. For guidance on managing cookies in your browser, refer to your browser's help documentation.

10. Minors

The 92jl Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 92jl does not knowingly collect personal data from individuals under the age of 21.

If 92jl becomes aware that personal data has been collected from a person under 21 years of age, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact us immediately at the details provided in Section 14.

11. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 92jl:

• Right to Be Informed: You have the right to be informed of how your personal data is being processed, as set out in this Policy.
• Right to Access: You may request a copy of the personal data 92jl holds about you, along with information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held by 92jl.
• Right to Erasure / Right to be Forgotten: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 92jl's legal retention obligations.
• Right to Object: You may object to the processing of your personal data where processing is based on legitimate interest or for direct marketing purposes.
• Right to Data Portability: You may request that 92jl provide your personal data in a structured, commonly used, and machine-readable format.
• Right to Damages: You have the right to claim compensation for any damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that 92jl has violated your data privacy rights.

To exercise any of the above rights, please contact the 92jl Data Protection Officer using the details in Section 14. 92jl will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

12. Cross-Border Data Transfers

92jl primarily stores and processes your personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure partners located outside the Philippines, 92jl ensures that such transfers are carried out in compliance with Section 21 of the Data Privacy Act and the NPC's rules on cross-border data transfers.

Specifically, 92jl will only transfer personal data outside the Philippines where:

• The recipient country has been assessed to provide an adequate level of data protection; or
• Appropriate safeguards are in place, such as contractual clauses approved by the NPC; or
• The transfer is necessary for the performance of your contract with 92jl (e.g., processing a payment through an international payment network).

13. Changes to This Privacy Policy

92jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material, 92jl will notify registered players via email or an in-Platform notification at least seven (7) 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.

We encourage you to review this Policy periodically to stay informed about how 92jl protects your personal information.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by 92jl, please contact our Data Protection Officer: