Privacy Policy – 25jl Casino

1. Who We Are

25jl operates the online gaming platform accessible at 25jl.asia. 25jl holds a gaming license issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to Philippine law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations administered by the National Privacy Commission (NPC).

For the purposes of this Privacy Policy, 25jl acts as the Personal Information Controller in respect of the personal data of its registered players and website visitors, as that term is defined under the Data Privacy Act of 2012.

Questions or requests relating to this Privacy Policy or your personal data may be directed to 25jl's Data Protection Officer via the contact details in Section 13 of this policy.

2. Personal Data We Collect

25jl collects personal data in the following categories depending on your level of interaction with the platform:

25jl does not collect sensitive personal information (as defined under the Data Privacy Act of 2012, e.g., health data, political affiliations, religious beliefs) unless this is directly relevant to a responsible gaming assessment or is voluntarily provided by the Player in a support context.

3. How We Use Your Personal Data

25jl uses the personal data it collects for the following purposes:

• Account registration and management: Creating, verifying, and maintaining your 25jl account; authenticating login sessions; providing account recovery assistance.
• Identity verification (KYC): Verifying your identity, age, and Philippine residency as required by PAGCOR's licensing conditions and Philippine anti-money laundering law.
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, and Philippine banking channels; reconciling transaction records; investigating payment disputes.
• Platform operation: Delivering games, calculating game outcomes, recording bet history, applying bonus offers, operating loyalty programs, and providing all platform services.
• Legal and regulatory compliance: Meeting 25jl's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and all other applicable Philippine law.
• Fraud prevention and security: Detecting and preventing fraudulent account activity, multi-accounting, bonus abuse, money laundering, and other prohibited conduct described in 25jl's Terms & Conditions.
• Responsible gaming: Monitoring gaming patterns for indicators of problem gambling; applying player-requested deposit limits, self-exclusion orders, and cooling-off periods; fulfilling PAGCOR's responsible gaming obligations.
• Customer support: Responding to player queries, resolving complaints, processing dispute escalations to PAGCOR, and maintaining support records.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to Players who have opted in to marketing communications. You may opt out at any time.
• Platform improvement: Analysing aggregated, anonymised usage data to improve platform performance, user experience, and game selection.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 25jl processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to perform the contract between 25jl and you as a registered Player (account management, game delivery, payment processing).
• Legal obligation: Processing required to comply with PAGCOR licensing requirements, AMLA obligations, NPC directives, and other applicable Philippine law.
• Legitimate interests: Processing necessary for 25jl's legitimate business interests, including fraud prevention, security monitoring, and platform improvement, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and optional analytics features, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

25jl does not sell, rent, or trade your personal data to third parties for their independent marketing purposes. Personal data is shared only in the following circumstances:

• PAGCOR and regulatory authorities: 25jl is legally required to provide player data and transaction records to PAGCOR upon request as a condition of its gaming license. Data is also shared with the Anti-Money Laundering Council (AMLC) and other Philippine authorities when legally compelled.
• Payment processors: Financial data is shared with GCash (G-Xchange Inc.), PayMaya (Maya Bank), BPI, BDO, Metrobank, and other payment partners strictly to the extent required to process your deposit or withdrawal transaction.
• Identity verification providers: KYC documentation may be processed by third-party identity verification service providers engaged by 25jl, who are contractually bound to process such data only for KYC purposes and under confidentiality obligations.
• Game providers: Technical session data (but not identity or financial data) is shared with 25jl's licensed game suppliers (e.g., JILI, Pragmatic Play, PG Soft) solely for the purpose of delivering and recording game outcomes.
• Law enforcement: 25jl will disclose personal data to Philippine law enforcement agencies when required by a valid court order, subpoena, or other lawful process.
• Professional advisors: Data may be shared with 25jl's legal, accounting, or audit advisors under strict confidentiality obligations where necessary for professional services.

6. Data Retention

25jl retains personal data for the following periods:

• Active account data: Retained for the duration of the Player's account and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and AMLA obligations.
• Transaction records: Financial transaction records are retained for a minimum of ten (10) years as required by Philippine anti-money laundering regulations.
• KYC documents: Retained for five (5) years after account closure or the last transaction, whichever is later.
• Support communications: Live chat transcripts and email records are retained for three (3) years from the date of the communication.
• Marketing consent records: Retained for the duration of the consent and for two (2) years thereafter as evidence of compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised, aggregated data (which cannot identify any individual Player) may be retained indefinitely for statistical analysis and platform improvement.

7. Data Security

25jl implements organisational and technical security measures appropriate to the sensitivity of the personal data it processes. These measures include:

• SSL/TLS encryption for all data transmitted between the Player's device and the 25jl platform
• Encryption at rest for all databases containing personal and financial data
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis
• Two-factor authentication requirements for all 25jl staff accessing production systems containing player data
• Regular independent security audits and penetration testing of platform infrastructure
• Incident response procedures for data security breaches, including NPC notification within 72 hours of becoming aware of a breach affecting personal data

While 25jl takes all reasonable steps to protect your personal data, no data transmission or storage system is completely secure. Players should also take responsibility for their own account security by using strong, unique passwords and enabling OTP two-factor authentication on their 25jl accounts.

8. Cookies & Tracking Technologies

25jl uses cookies and similar tracking technologies on the 25jl.asia platform for the following purposes:

• Strictly necessary cookies: Required for platform operation, including session authentication, load balancing, and security functions. These cannot be disabled without preventing platform use.
• Functional cookies: Store Player preferences such as language settings, preferred game categories, and display options to personalise the platform experience.
• Analytics cookies: Collect aggregated, anonymised data about how Players navigate and use the platform to help 25jl identify and fix performance issues and improve user experience. No individual Player is identified through analytics data.

25jl does not use third-party advertising cookies or share tracking data with advertising networks. Players may manage cookie preferences through their browser settings. Disabling strictly necessary cookies will affect platform functionality.

9. Your Data Protection Rights

Under the Data Privacy Act of 2012, registered Players have the following rights in respect of their personal data held by 25jl:

• Right to be informed: You have the right to know what personal data 25jl holds about you and how it is being used. This Privacy Policy fulfils that obligation.
• Right of access: You may request a copy of the personal data 25jl holds about you. Requests are fulfilled within thirty (30) calendar days.
• Right to rectification: You may request correction of inaccurate or incomplete personal data. For basic account data, this can be done directly through your account settings.
• Right to erasure: In certain circumstances, you may request deletion of your personal data. This right is subject to override by 25jl's legal data retention obligations under PAGCOR regulations and Philippine law.
• Right to object: You may object to processing based on legitimate interests, including marketing communications. Opting out of marketing communications can be done at any time.
• Right to data portability: You may request a machine-readable copy of personal data you have provided to 25jl, where technically feasible.
• Right to file a complaint: If you believe 25jl has mishandled your personal data, you may file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, contact 25jl's Data Protection Officer via the details in Section 13. 25jl will verify your identity before processing any data rights request.

10. Children & Minors

If 25jl becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately closed, all balances returned to the payment source, and all personal data associated with the account securely deleted, except where retention is required by law for investigation purposes.

If you are a parent or guardian and believe that a minor in your care has registered on 25jl, please contact 25jl support immediately via Live Chat or email so that the matter can be addressed urgently.

11. Cross-Border Data Transfers

Some of 25jl's technical infrastructure, game provider partners, and service providers may process or store data outside the Philippines. Where personal data is transferred outside the Philippines, 25jl ensures that appropriate safeguards are in place as required by Section 21 of the Data Privacy Act of 2012 and NPC guidelines, including:

• Standard contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under Philippine law
• Transfer only to recipients in jurisdictions with adequate data protection frameworks as recognised by the NPC
• Contractual binding of game providers and technology partners to data processing restrictions that limit use of Player data to the specific service being provided

Financial data processed by Philippine payment providers (GCash, PayMaya, BPI, BDO, Metrobank) is processed within the Philippines in accordance with Bangko Sentral ng Pilipinas (BSP) regulations.

12. Policy Updates

25jl may update this Privacy Policy from time to time to reflect changes in our data processing practices, Philippine legal requirements, PAGCOR regulatory obligations, or NPC guidance. Material changes will be communicated to registered Players via the email address on file and/or via a notification displayed on the platform.

The "Last Updated" date at the top of this policy reflects the date of the most recent revision. Continued use of the 25jl platform following publication of a material update constitutes acceptance of the revised Privacy Policy. If you do not agree with any update, you may request account closure in accordance with 25jl's Terms & Conditions.

13. Contact – Data Protection Officer

For any queries, requests, or complaints relating to this Privacy Policy or the handling of your personal data by 25jl, please contact our Data Protection Officer through the following channels:

Unresolved privacy complaints may also be escalated to the National Privacy Commission of the Philippines (privacy.gov.ph) or to PAGCOR's player protection division for matters involving gaming regulatory compliance.