Privacy Policy for 90JL

90JL ("we," "us," "our") is committed to protecting the privacy and personal data of every player who uses our platform. This Privacy Policy describes how 90JL collects, processes, stores, and protects personal information in connection with the operation of the 90JL online gaming platform, accessible at 90jl.app.

This Privacy Policy applies to all personal data collected through the 90JL website, mobile application, customer support channels, and any other interaction you have with the 90JL platform. It should be read together with our Terms and Conditions, which govern your use of the platform as a whole.

By registering an account on 90JL or otherwise using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, you must not use the 90JL platform.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, 90JL is the personal information controller responsible for the personal data collected through the 90JL platform.

90JL has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data privacy laws. Contact details for the DPO are provided in Section 14 of this Policy.

90JL collects the following categories of personal data in connection with the operation of the platform:

90JL does not collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect data relating to your health, political opinions, religious beliefs, or sexual orientation.

90JL collects personal data through the following means:

• Direct registration: Information you provide when creating your 90JL account, including your name, email address, mobile number, and date of birth.
• KYC verification: Identity documents and supporting materials you submit to complete account verification, either at registration or upon request.
• Payment transactions: Financial details captured when you make a deposit or request a withdrawal via GCash, PayMaya, BPI, BDO, Metrobank, or other supported payment channels.
• Platform activity: Data generated automatically as you use the 90JL platform, including game sessions, bet placements, login timestamps, and navigation patterns.
• Customer support interactions: Records of communications between you and the 90JL support team, including chat logs, emails, and call recordings where applicable.
• Cookies and tracking technologies: Technical data collected automatically through cookies, web beacons, and similar technologies when you access the 90JL website or app. See Section 10 for full details.
• Third-party sources: In limited circumstances, 90JL may receive data about you from third-party identity verification providers, payment processors, or fraud prevention services engaged to support our compliance obligations.

90JL uses the personal data we collect for the following purposes:

• Account management: Creating, maintaining, and securing your 90JL account, including processing login requests and managing account settings.
• Identity and age verification: Confirming that you meet the minimum age requirement of 21 years and verifying your identity in compliance with PAGCOR KYC requirements.
• Payment processing: Facilitating deposits and withdrawals, reconciling transactions, and investigating payment disputes.
• Regulatory compliance: Meeting our obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act, and other applicable Philippine laws, including reporting obligations to the Anti-Money Laundering Council (AMLC).
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior and administering self-exclusion, deposit limit, and cooling-off requests.
• Customer support: Responding to your inquiries, resolving complaints, and providing technical assistance.
• Platform improvement: Analyzing aggregated usage data to improve game performance, user experience, and platform features.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates, where you have provided consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time through your account settings.

Under the Philippine Data Privacy Act of 2012, 90JL processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you agreed to when registering your 90JL account, including account management, payment processing, and game operation.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act itself, and other applicable Philippine laws and regulations.
• Legitimate interests: Processing carried out for 90JL's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent, particularly in relation to marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

90JL does not share your personal data with third parties except in the following circumstances:

• Payment service providers: We share necessary financial data with GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors to facilitate deposits and withdrawals. These providers are contractually bound to process your data only for the purpose of completing your transaction.
• Identity verification providers: We engage third-party KYC and identity verification services to assist with document verification and fraud screening. These providers act as data processors under our instruction and are bound by strict data processing agreements.
• Regulatory authorities: We are required by law to disclose certain data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities upon lawful request or as required by our licensing conditions.
• Fraud prevention and security services: We may share technical and account data with fraud prevention platforms to detect and prevent unauthorized access, money laundering, and other illegal activity.
• Legal proceedings: We may disclose personal data where required by a court order, subpoena, or other lawful legal process issued by a competent Philippine authority.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 90JL's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

90JL retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following retention periods:

• Account data: Retained for the duration of your account's active status and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements.
• Transaction and financial records: 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.
• KYC and identity documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer support records: Retained for three (3) years from the date of the interaction, or longer where the interaction relates to an unresolved dispute or legal proceeding.
• Marketing consent records: Retained for as long as you remain a registered 90JL player, and for one (1) year following account closure or withdrawal of consent.
• Technical and log data: Retained for up to twelve (12) months, unless a longer retention period is required for security investigation or legal purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 90JL's data disposal procedures.

90JL implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 90JL platform.
• Encryption of sensitive data at rest, including financial records and identity documents.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Regular security audits, vulnerability assessments, and penetration testing conducted by independent security professionals.
• Incident response procedures for detecting, containing, and reporting personal data breaches in accordance with the Data Privacy Act's 72-hour notification requirement.

While 90JL takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

90JL uses cookies and similar tracking technologies on its website and mobile application. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how you use the platform.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the 90JL platform, helping us identify areas for improvement. This data does not identify you personally.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings or through the cookie consent tool available on the 90JL platform. Please note that disabling certain cookies may affect the functionality of the platform.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 90JL:

• Right to be informed: The right to know what personal data 90JL collects about you, how it is used, and with whom it is shared — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data 90JL holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held by 90JL.
• Right to erasure: 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 any legal retention obligations that apply.
• Right to object: 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: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to request its transfer to another service provider where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe that 90JL has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14. We will respond to all verified requests within fifteen (15) business days. In complex cases, we may extend this period by a further fifteen (15) business days, with prior notice to you.

The 90JL platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing real-money online gaming in the Philippines. 90JL does not knowingly collect personal data from individuals under the age of 21.

If 90JL discovers or has reason to believe that an account has been registered by a person under 21 years of age, we will immediately suspend the account, delete all associated personal data to the extent permitted by law, and return any deposited funds to the payment source used.

If you are a parent or guardian and believe that a minor has registered an account on 90JL using your payment details or personal information, please contact our support team immediately at the contact details provided in Section 14. We will investigate and take appropriate action promptly.

90JL reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or PAGCOR regulatory requirements. The most current version of this Privacy Policy will always be available on this page, with the "Last Updated" date reflecting the date of the most recent revision.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — 90JL will notify registered players via the email address or mobile number associated with their account at least fourteen (14) days before the changes take effect. Your continued use of the 90JL platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 90JL protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 90JL, please contact our Data Protection Officer through the following channels:

• Data Protection Officer: [email protected]
• General Privacy Inquiries: [email protected]
• General Support: [email protected]

Our DPO is available during Philippine business hours (Monday to Friday, 9:00 AM to 6:00 PM PHT) and will acknowledge all privacy-related inquiries within two (2) business days. Formal data rights requests will be processed within fifteen (15) business days of identity verification.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC) through its official channels.