Privacy Policy

1. Who We Are

ljl3 is an online gaming platform operated for the benefit of Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Iloilo, and beyond. For the purposes of the Data Privacy Act of 2012 (RA 10173), ljl3 acts as the Personal Information Controller in respect of the personal data it collects from registered players and Platform visitors.

If you have any questions about this Policy or wish to exercise your data privacy rights, you may contact our Data Protection Officer (DPO) via the support channels described in Section 10 of this Policy.

2. Personal Data We Collect

ljl3 collects personal data from you in the following circumstances:

2.1 Registration and KYC Data

• Full legal name as it appears on your government-issued Philippine ID;
• Date of birth (to verify the 21+ age requirement);
• Philippine mobile number and email address;
• Residential address in the Philippines;
• Government-issued ID documents (e.g., PhilSys ID, passport, driver's license, UMID, SSS ID, voter's ID);
• Selfie or liveness verification image where required for KYC.

2.2 Financial and Transaction Data

• GCash or Maya mobile wallet number;
• Bank account details (account name, account number, bank name) for withdrawal processing;
• Deposit and withdrawal transaction history;
• Wagering history and game activity records.

2.3 Technical and Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session logs, login timestamps, and Platform navigation data;
• Cookie identifiers and session tokens (see Section 8).

2.4 Communications Data

• Records of live chat, email, and support ticket interactions with the ljl3 team;
• Responses to surveys, promotions, or feedback requests where you choose to participate.

3. How We Use Your Personal Data

ljl3 uses the personal data we collect for the following purposes:

• Account creation and management: To register your ljl3 account, verify your identity, and maintain your player profile;
• Age and eligibility verification: To confirm that you meet the 21+ age requirement and are eligible to use the Platform under Philippine law;
• Payment processing: To process deposits and withdrawals via GCash, Maya, and Philippine bank transfers in Philippine Peso (PHP);
• Regulatory compliance: To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations under RA 9160, and other applicable Philippine laws;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account takeovers, and other security threats;
• Customer support: To respond to your queries, complaints, and support requests;
• Responsible gaming: To monitor gaming patterns and proactively offer responsible gaming tools where appropriate;
• Platform improvement: To analyse usage patterns and improve the ljl3 Platform, game offerings, and user experience;
• Marketing communications: To send you promotional offers and updates about ljl3, where you have provided consent. You may opt out at any time.

4. Legal Basis for Processing

ljl3 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform our obligations under the ljl3 Terms & Conditions, including account management and payment processing;
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, PAGCOR requirements, and tax obligations;
• Legitimate interests: Processing for fraud prevention, Platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. Consent may be withdrawn at any time.

5. Data Sharing and Disclosure

ljl3 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:

• Payment processors: GCash, Maya, and Philippine banking partners, solely for the purpose of processing your deposits and withdrawals;
• KYC and identity verification providers: Third-party identity verification services used to fulfil our KYC obligations;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies where disclosure is required by law;
• IT and infrastructure providers: Cloud hosting and cybersecurity service providers who process data on our behalf under strict data processing agreements;
• Professional advisers: Legal, accounting, and compliance advisers bound by professional confidentiality obligations.

All third-party service providers engaged by ljl3 are required to implement appropriate technical and organisational measures to protect your personal data and to process it only in accordance with our instructions.

6. Data Retention

6.1 ljl3 retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law. Specifically:

• Account and KYC records are retained for a minimum of five (5) years following account closure, in compliance with AML regulations under RA 9160;
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Support and communications records are retained for three (3) years from the date of the interaction;
• Technical and usage logs are retained for twelve (12) months on a rolling basis.

6.2 Upon expiry of the applicable retention period, ljl3 will securely delete or anonymise your personal data in accordance with our internal data disposal procedures.

7. Your Data Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in respect of your personal data held by ljl3:

• Right to be informed: The right to know what personal data ljl3 holds about you and how it is being used;
• Right of access: The right to request a copy of the personal data ljl3 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint: The right to file 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 our Data Protection Officer via the support channels described in Section 10. We will respond to all verified requests within fifteen (15) business days in accordance with NPC guidelines.

8. Cookies and Tracking Technologies

8.1 ljl3 uses cookies and similar technologies to operate the Platform, maintain your session, and ensure Platform security. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens and security cookies. These cannot be disabled.
• Performance cookies: Used to analyse how players use the Platform so we can improve functionality and game performance. Data collected is aggregated and anonymised.
• Preference cookies: Used to remember your language and display preferences across sessions.

8.2 ljl3 does not use third-party advertising cookies, cross-site tracking pixels, or social media tracking technologies. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair Platform functionality.

9. Data Security

ljl3 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the ljl3 Platform;
• Encrypted storage of sensitive personal and financial data at rest;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security audits and vulnerability assessments of Platform infrastructure;
• Multi-factor authentication options for player accounts.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ljl3 will notify the National Privacy Commission and affected players in accordance with the timelines prescribed under the Data Privacy Act and NPC Circular No. 16-03.

10. Contact Our Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data privacy rights, or wish to raise a concern about how ljl3 handles your personal data, please contact our Data Protection Officer:

[email protected]

Our support team is available 24/7 and includes Filipino-speaking staff ready to assist players from Manila, Cebu, Davao, Quezon City, Makati, and all across the Philippines. We aim to acknowledge all privacy-related enquiries within two (2) business days and to resolve them within fifteen (15) business days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.