989jl Privacy Policy

1 About This Policy

989jl ("we," "us," or "our") is committed to protecting the personal data of all individuals who interact with our platform. This Privacy Policy has been prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC).

As a personal information controller, 989jl determines the purposes and means by which your personal data is processed. We process your data lawfully, fairly, and transparently, and only for the specific purposes described in this Policy. We do not sell your personal data to third parties for their own marketing purposes.

This Policy should be read alongside the 989jl Terms & Conditions and Responsible Gaming Policy, both of which form part of your agreement with 989jl.

2 Data We Collect

989jl collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of data we collect include:

Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (to verify you are 21 years of age or older);
• Philippine mobile number and email address;
• Residential address (province, city/municipality, barangay);
• Government-issued ID details (e.g., Philippine passport, SSS ID, UMID, driver's license, PhilSys national ID number).

Financial Data

• GCash or PayMaya account details (mobile number associated with the e-wallet);
• Bank account details for bank transfer transactions (account name, account number, bank name);
• Debit card details (card number, expiry — stored in tokenized form only);
• Transaction history including deposits, withdrawals, and wager records.

Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, pages visited, and features used on the 989jl platform;
• Login timestamps and account activity logs.

Communications Data

• Records of your communications with the 989jl support team via live chat, email, or other channels;
• Responses to surveys, promotions, or feedback requests.

989jl does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive data is collected (such as government ID numbers), it is handled with the highest level of security and access controls.

3 How We Use Your Data

989jl uses your personal data for the following purposes:

• Account Registration & Verification: To create and manage your 989jl account, verify your identity, and confirm that you meet the 21+ age requirement;
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of 989jl platform features;
• Regulatory Compliance: To comply with anti-money laundering (AML) obligations, counter-terrorism financing (CTF) requirements, and other applicable Philippine laws and regulations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats;
• Responsible Gaming: To monitor gaming patterns, enforce responsible gaming tools such as deposit limits and self-exclusion, and identify players who may need support;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Marketing & Promotions: To send you information about 989jl promotions, bonuses, and new features — but only where you have given your consent or where we have a legitimate interest to do so. You may opt out of marketing communications at any time;
• Platform Improvement: To analyze usage patterns and improve the 989jl platform, user experience, and game offerings;
• Legal Proceedings: To establish, exercise, or defend legal claims where necessary.

989jl will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

4 Legal Basis for Processing

Under the Data Privacy Act of 2012, 989jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — i.e., to provide the 989jl gaming services you have registered for;
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML/CTF regulations, tax obligations, and NPC reporting requirements;
• Legitimate Interests: Processing is necessary for 989jl's legitimate interests, such as fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and freedoms;
• Consent: For certain processing activities — such as marketing communications and the use of non-essential cookies — we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Sharing Your Data

989jl does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, and Philippine banking partners, to process your deposits and withdrawals;
• Game Providers: Third-party game studios whose titles are hosted on the 989jl platform, to the extent necessary to deliver gameplay and resolve disputes;
• Identity Verification Providers: KYC and AML compliance service providers who assist with identity verification and fraud screening;
• IT & Cloud Service Providers: Technology partners who provide hosting, data storage, and platform infrastructure services under strict data processing agreements;
• Regulatory Authorities: The National Privacy Commission, PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law;
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid legal order or where we believe disclosure is necessary to prevent fraud, illegal activity, or harm to persons;
• Professional Advisers: Lawyers, auditors, and accountants, where necessary for the conduct of 989jl's business and subject to professional confidentiality obligations.

All third parties with whom 989jl shares personal data are required to handle that data in accordance with applicable data protection laws and 989jl's data protection standards. 989jl does not transfer personal data outside the Philippines except where necessary and subject to appropriate safeguards.

6 Cookies & Tracking Technologies

989jl uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Essential Cookies: Required for the platform to function correctly, including session management, login authentication, and security features. These cannot be disabled;
• Analytics Cookies: Used to understand how players interact with the 989jl platform, which pages are most visited, and where technical issues occur. This data is aggregated and anonymized;
• Preference Cookies: Used to remember your settings and preferences, such as language and display options;
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may affect the functionality of the 989jl platform. For more information on how to manage cookies, refer to your browser's help documentation.

7 Data Retention

989jl retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AML record-keeping requirements under Philippine law;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction;
• KYC Documents: Retained for the duration of the account relationship and for five (5) years thereafter;
• Support Communications: Retained for three (3) years from the date of the last communication;
• Marketing Consent Records: Retained until you withdraw your consent, plus a reasonable period thereafter for compliance purposes.

When personal data is no longer required, 989jl will securely delete or anonymize it in accordance with our data disposal procedures.

8 Data Security

989jl implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the 989jl platform;
• Encryption of sensitive data at rest, including financial information and government ID details;
• Multi-factor authentication for account access and administrative systems;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Strict access controls ensuring that only authorized personnel can access personal data, on a need-to-know basis;
• Staff training on data protection obligations and security best practices;
• Incident response procedures to detect, report, and address personal data breaches promptly.

While 989jl takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 989jl will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

You also play an important role in keeping your data secure. Please ensure you use a strong, unique password for your 989jl account, enable two-factor authentication where available, and never share your login credentials with anyone.

9 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 989jl:

• Right to Be Informed: You have the right to be informed of how your personal data is being collected, processed, and used — which is the primary purpose of this Privacy Policy;
• Right of Access: You have the right to request a copy of the personal data 989jl 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;
• Right to Erasure or Blocking: You have the right to request the deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful — subject to 989jl's legal retention obligations;
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• 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 Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated. The NPC can be reached through its official website at privacy.gov.ph.

To exercise any of these rights, please contact the 989jl Data Protection Officer using the contact details provided in Section 12 of this Policy. 989jl will respond to all data subject requests within fifteen (15) business days of receipt. In complex cases, this period may be extended by a further fifteen (15) business days, and you will be notified accordingly.

10 Children's Privacy

989jl does not direct any of its services, marketing, or content toward minors. All new account registrations are subject to age verification, and 989jl reserves the right to request documentary proof of age at any time. If 989jl discovers that personal data has been collected from an individual under the age of 21, that account will be immediately suspended, the data will be deleted, and the matter will be referred to the appropriate authorities where required.

If you are a parent or guardian and believe that your child has registered an account on 989jl or provided personal data to us, please contact our support team immediately so that we can take appropriate action.

11 Changes to This Privacy Policy

989jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. 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 as a data subject — 989jl will notify registered players via their registered email address or mobile number at least fourteen (14) days before the changes take effect. For minor or administrative updates, the revised Policy will simply be posted on this page with an updated effective date.

Your continued use of the 989jl platform after any amendment to this Privacy Policy constitutes your acknowledgment of the revised Policy. If you do not agree with the changes, you may request the closure of your account by contacting the 989jl support team.

12 Contact & Data Protection Officer

989jl has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO:

Data Protection Officer — 989jl

Email: [email protected]

General Support: [email protected]

Our DPO is available Monday to Friday, 9:00 AM to 6:00 PM Philippine Standard Time (PST). For urgent data security concerns — such as suspected unauthorized access to your account — please contact our 24/7 support team directly.