jltt Privacy Policy

1. Introduction

jltt is committed to protecting the privacy and personal data of every member who uses our online gaming platform. This Privacy Policy applies to all personal information collected through jltt.org, our mobile web experience, customer support channels, and any other touchpoints through which you interact with jltt.

This Policy is intended to be clear, transparent, and easy to understand. We know that privacy policies can be dense — so we have structured this document to give you a plain-language explanation of each topic, followed by the more detailed legal provisions where necessary. If anything in this Policy is unclear, please contact our support team before using the platform.

This Privacy Policy should be read alongside the jltt Terms & Conditions, which govern the overall relationship between you and jltt. In the event of any conflict between this Policy and the Terms & Conditions with respect to data handling, this Privacy Policy shall take precedence.

2. Information We Collect

jltt collects personal information in several ways: directly from you when you register or use the platform, automatically through your device and browser, and from trusted third-party sources where permitted by law. The categories of information we collect are described below.

2.1 Information You Provide Directly

• Registration data: Full legal name, date of birth, residential address in the Philippines (including city — whether Metro Manila, Cebu, Davao, Quezon City, Makati, or elsewhere), email address, and mobile number.
• Identity verification documents: Government-issued Philippine ID (e.g., PhilSys National ID, Passport, Driver's Licence, SSS ID, UMID, Voter's ID, PRC ID), selfie photographs, and proof of address submitted during KYC verification.
• Payment information: Bank account details, GCash or Maya account references, and other payment method identifiers necessary to process deposits and withdrawals in Philippine Peso (PHP).
• Communications: Records of your interactions with jltt customer support, including live chat transcripts, email correspondence, and feedback submissions.
• Preferences and settings: Responsible gaming limits, notification preferences, and any other account configuration data you set within your jltt profile.

2.2 Information Collected Automatically

• Device and browser data: IP address, device type, operating system, browser version, screen resolution, and language settings.
• Usage data: Pages visited, games played, session duration, wagering activity, deposit and withdrawal history, and clickstream data within the jltt platform.
• Cookies and similar technologies: Session cookies, persistent cookies, and local storage tokens used to maintain your login session and personalise your experience. See Section 6 for full details.
• Geolocation data: Approximate location derived from your IP address, used to comply with jurisdictional restrictions and prevent access from prohibited territories.

2.3 Information from Third Parties

• Identity verification providers: Third-party KYC and AML screening services may provide results of identity checks, sanctions list screening, and politically exposed person (PEP) status checks.
• Payment processors: Transaction confirmation data from GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other payment partners to verify deposits and process withdrawals.
• Fraud prevention services: Risk scoring and device fingerprinting data from fraud detection partners used to protect jltt and its members from account takeover and financial crime.

3. How We Use Your Data

jltt uses the personal information we collect for the following purposes:

Purpose	Description
Account management	Creating and maintaining your jltt account, verifying your identity, and providing access to platform features.
Transaction processing	Processing deposits, withdrawals, and bonus credits in PHP via your chosen payment method.
Regulatory compliance	Meeting PAGCOR licensing obligations, AML/CFT requirements, age verification, and other applicable Philippine regulatory mandates.
Fraud prevention	Detecting and preventing fraudulent transactions, bonus abuse, money laundering, and unauthorised account access.
Customer support	Responding to your enquiries, resolving disputes, and improving the quality of our support interactions.
Responsible gaming	Monitoring gaming behaviour to identify problem gambling indicators and enforcing self-imposed limits and exclusions.
Platform improvement	Analysing aggregate usage data to improve platform performance, game selection, and user experience.
Marketing (with consent)	Sending promotional offers, bonus notifications, and product updates to members who have opted in to marketing communications.

4. Legal Basis for Processing

jltt processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to fulfil the jltt membership agreement, including account creation, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and PAGCOR regulations, including AML, KYC, and age verification requirements.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and the improvement of jltt's services, where such interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications, certain cookie usage, and any other purpose where we have explicitly requested and obtained your consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Third Parties

jltt does not sell your personal data. We share your information only in the following limited circumstances:

5.1 Service Providers

We engage trusted third-party service providers to assist in operating jltt, including payment processors (GCash, Maya, BPI, BDO, Metrobank, UnionBank, Visa, Mastercard), KYC/AML verification providers, fraud detection platforms, game content providers, cloud hosting services, and customer support tools. These providers access your data only as necessary to perform their contracted services and are prohibited from using it for any other purpose.

5.2 Regulatory & Law Enforcement Authorities

jltt may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government authorities where required by law, court order, or regulatory direction. We will notify you of such disclosures where legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving jltt, your personal data may be transferred to the relevant successor entity as part of that transaction. We will provide notice of any such transfer and the applicable privacy terms before the transfer takes effect.

6. Cookies & Tracking Technologies

jltt uses cookies and similar technologies to operate the platform, remember your preferences, and analyse usage patterns. The types of cookies we use are:

• Essential cookies: Required for the platform to function correctly, including maintaining your login session and remembering your language preference. These cannot be disabled without impairing platform functionality.
• Performance cookies: Collect anonymised data about how pages are used — such as which games are most popular and where users experience errors — to help us improve platform performance.
• Functional cookies: Remember personalisation choices you have made, such as preferred deposit method or display settings, to improve your experience on return visits.
• Security cookies: Used to detect fraudulent login attempts, session hijacking, and other security threats. These cookies are essential to protecting your jltt account.

You can control non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of specific jltt features. jltt does not use third-party advertising cookies or cross-site tracking technologies.

7. Data Retention

jltt retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your membership and for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing and AML record-keeping requirements.
• Transaction records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction in compliance with Philippine AML regulations.
• KYC documents: Identity verification documents are retained for the period required by PAGCOR and AML/CFT regulations, typically five (5) years from account closure.
• Customer support records: Support interaction records are retained for three (3) years from the date of the interaction, or longer where relevant to an unresolved dispute.
• Marketing data: Marketing opt-in records and communication history are retained for two (2) years from your last interaction, or until you withdraw consent, whichever comes first.

When personal data is no longer required, jltt will securely delete or anonymise it in a manner that prevents reconstruction.

8. Data Security

jltt implements a comprehensive set of technical and organisational security measures designed to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jltt servers
• Encryption of sensitive data fields at rest within jltt's databases
• PCI-DSS compliant payment processing for all card and e-wallet transactions
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular penetration testing and security audits conducted by qualified third-party security firms
• Multi-factor authentication requirements for all jltt internal systems that handle member data
• Real-time intrusion detection and monitoring of jltt infrastructure
• Documented data breach response procedures with mandatory notification timelines

In the event of a personal data breach that poses a risk to your rights and freedoms, jltt will notify the Philippine National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected members without undue delay where required by law.

9. Your Rights

As a jltt member and data subject under applicable Philippine privacy law, you have the following rights with respect to your personal data:

• Right to access: You may request a copy of the personal data jltt holds about you, along with information about how it is being used.
• Right to correction: You may request that we correct any inaccurate or incomplete personal data we hold about you. Many corrections can be made directly through your jltt account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jltt's legal retention obligations.
• Right to data portability: You may request a copy of the personal data you provided to jltt in a structured, commonly used, machine-readable format.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to other processing based on legitimate interests.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe jltt has mishandled your personal data.

To exercise any of these rights, please contact the jltt data protection team via the support email published in the footer of this page. We will acknowledge your request within 72 hours and provide a substantive response within 30 calendar days. Complex or multiple requests may take longer, in which case we will notify you of the extended timeline.

10. Children & Minors

jltt is strictly intended for users aged 21 years and above. We do not knowingly collect personal information from individuals under the age of 21. If jltt becomes aware that personal data has been collected from a person under 21, we will immediately close the relevant account, delete the associated data, and refund any deposited funds to the source account.

Parents and guardians who believe their child has registered on jltt should contact our support team immediately. We will investigate and act on all such reports as a matter of priority.

11. International Data Transfers

jltt primarily processes and stores personal data within the Philippines or in jurisdictions that provide an adequate level of data protection. Where data is transferred to a third-party service provider located outside the Philippines — for example, cloud hosting infrastructure or international payment networks — jltt ensures that appropriate contractual safeguards are in place to protect your data to a standard equivalent to Philippine privacy law requirements.

By using jltt, you acknowledge that your personal data may be processed in jurisdictions outside the Philippines as described above, subject to the safeguards described in this section.

12. Changes to This Privacy Policy

jltt may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable legal requirements. When we make material changes, we will notify you by email to your registered address and/or by a prominent notice on the jltt platform prior to the changes taking effect. The "Last updated" date at the top of this page will always reflect the most recent revision.

We encourage you to review this Privacy Policy periodically. Your continued use of jltt following notification of any changes constitutes your acknowledgement of the updated Policy. If you do not agree with any changes, you should stop using jltt and may request account closure in accordance with the Terms & Conditions.

13. Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way jltt handles your personal data, please contact our data protection team. We are available 24/7 via live chat on the jltt platform. For formal written enquiries, please use the support email address published in the footer of this page, and mark your message "Privacy — Data Request" or "Privacy — Complaint" as appropriate.

If you are not satisfied with jltt's response to your privacy concern, you have the right to escalate your complaint to the Philippine National Privacy Commission (NPC). The NPC is the regulatory body responsible for enforcing the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

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