jlber Privacy Policy

1.1  This Privacy Policy ("Policy") is issued by jlber ("jlber", "we", "us", "our"), the operator of the online gaming platform accessible at jlber.vip (the "Platform"). It applies to all personal data collected from individuals who access or use the Platform, including registered players, prospective players who visit the website without registering, and any individual who communicates with jlber's customer support team.

1.2  This Policy is issued in compliance with the Data Privacy Act of 2012 of the Republic of the Philippines (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC). Where jlber processes data relating to individuals outside the Philippines, it applies equivalent standards consistent with applicable international privacy frameworks.

1.3  This Policy should be read in conjunction with jlber's Terms and Conditions and Responsible Gaming Policy, both of which reference the collection and use of personal data in specific contexts.

1.4  jlber may provide links to or integrations with third-party payment processors (including GCash, PayMaya, BPI, BDO, and Metrobank). This Policy does not extend to the privacy practices of those third parties. You should review the privacy policies of your payment provider independently.

2.1  For the purposes of the Data Privacy Act of 2012, jlber is the personal information controller (PIC) in respect of all personal data collected through the Platform. jlber determines the purposes for which personal data is processed and the means by which processing is carried out.

2.2  jlber has designated a Data Protection Officer (DPO) in accordance with Section 21 of the Data Privacy Act and the NPC's applicable circulars. The DPO is responsible for overseeing compliance with this Policy and applicable data privacy laws. The DPO may be contacted via the details set out in Section 14 of this Policy.

2.3  Where jlber engages third-party service providers to process personal data on its behalf — such as identity verification providers, payment processors, fraud detection services, and cloud infrastructure providers — those parties act as personal information processors (PIPs) under written data processing agreements that bind them to comply with the Data Privacy Act and this Policy.

3.1  jlber collects the following categories of personal data from players and site visitors:

3.2  jlber does not collect special categories of sensitive personal information (as defined under Section 3(l) of the Data Privacy Act) unless specifically required by a regulatory obligation or expressly consented to by the data subject. Where sensitive information is collected — such as government ID bearing a Philsys reference number — it is handled with heightened security controls and strict access limitations.

3.3  jlber does not knowingly collect personal data from individuals under 21 years of age. If we become aware that a minor has provided personal data, we will delete it promptly. See Section 11 for full details.

4.1  jlber processes personal data for the following specific purposes:

• Account Registration and Management: To create and maintain your jlber account, verify your identity, authenticate your login sessions, and manage account settings;
• KYC and Regulatory Compliance: To fulfil identity verification requirements mandated by PAGCOR, comply with the Anti-Money Laundering Act (AMLA), conduct source-of-funds checks, and respond to lawful regulatory requests;
• Payment Processing: To process your GCash, PayMaya, and bank transfer deposits and withdrawals, maintain a transaction ledger, and prevent payment fraud;
• Game Delivery and Account Integrity: To deliver the games and services you access on the Platform, maintain game fairness, and detect and prevent cheating, multi-accounting, or exploitation of bonuses;
• Responsible Gaming: To operate deposit limits, loss limits, session limits, and self-exclusion tools; to monitor for patterns of potentially problematic gambling behaviour in accordance with PAGCOR responsible gaming requirements;
• Fraud and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, money laundering, and other prohibited conduct;
• Customer Support: To respond to your enquiries, resolve disputes, and improve support quality through interaction analysis;
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates — only where you have not opted out and we have a lawful basis to do so;
• Platform Improvement: To analyse aggregated usage data, conduct performance testing, and improve the jlber Platform's features and user experience.

4.2  jlber will not use your personal data for purposes materially different from those listed above without providing prior notice and, where required by law, obtaining fresh consent.

5.1  Under the Data Privacy Act of 2012, jlber processes personal data on the following lawful grounds depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between jlber and the player (e.g., account creation, payment processing, game delivery);
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR regulatory requirements, AMLA obligations, and NPC data privacy directives;
• Consent: Processing for marketing communications, where we rely on your freely given, specific, and informed consent. You may withdraw marketing consent at any time without affecting the lawfulness of prior processing;
• Legitimate Interests: Processing for fraud prevention, platform security, and product improvement, where jlber's legitimate interests are not overridden by your privacy rights and freedoms.

5.2  Where jlber relies on consent as the legal basis for processing, you have the right to withdraw that consent at any time by contacting jlber's support team or updating your communication preferences in Account Settings. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

6.1  jlber does not sell, rent, or trade your personal data to third parties for their own commercial purposes. Your data is shared only in the following limited circumstances:

• Regulatory Authorities: jlber discloses personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other competent Philippine authorities where required by law, regulation, or lawful order;
• Payment Processors: Financial data necessary for deposit and withdrawal transactions is shared with GCash (G-Xchange Inc.), PayMaya (Voyager Innovations Inc.), BPI, BDO, Metrobank, and other licensed Philippine payment service providers solely for transaction processing purposes;
• Identity Verification Providers: KYC document data is shared with jlber's accredited identity verification service provider for the sole purpose of verifying your identity against government records. These providers are bound by data processing agreements prohibiting secondary use;
• Game Providers: Minimal technical data (session token, bet amounts, game outcomes) is shared with licensed game providers (such as JILI Games, PG Soft, Pragmatic Play) solely to deliver and validate game results. Game providers do not receive your name, contact details, or financial information;
• Cloud and Infrastructure Providers: jlber's platform data is hosted on secure cloud infrastructure. Infrastructure providers access data only as processors under strict contractual obligations;
• Legal Proceedings: Personal data may be disclosed to courts, law enforcement, or legal advisers where jlber is required to do so in connection with legal proceedings, regulatory investigations, or the enforcement of its Terms and Conditions.

6.2  Where jlber shares data with third-party processors, it ensures that appropriate data processing agreements are in place, binding those processors to process data only on jlber's instructions and in compliance with the Data Privacy Act.

7.1  jlber retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

7.2  After the applicable retention period expires, jlber will securely delete or anonymise your personal data so that it can no longer be used to identify you. Where immediate deletion is not technically feasible, data will be securely isolated until it can be deleted.

8.1  jlber implements technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption in Transit: All data transmitted between your device and jlber's servers is encrypted using TLS 1.2 or higher (SSL) — the same standard used by Philippine banks and licensed financial institutions;
• Encryption at Rest: Sensitive personal data stored in jlber's databases — including identity documents, payment references, and authentication credentials — is encrypted at rest using AES-256 or equivalent;
• Access Controls: Access to personal data is restricted to authorised jlber personnel on a strict need-to-know basis. All staff with data access undergo mandatory data privacy training and are bound by confidentiality obligations;
• Two-Factor Authentication: Players are strongly encouraged to enable 2FA on their accounts. Internal jlber systems require multi-factor authentication for all staff accessing production data;
• Security Monitoring: jlber operates continuous intrusion detection and security event monitoring systems. Anomalous access patterns trigger automated alerts and human investigation;
• Vulnerability Management: jlber conducts regular security assessments and penetration testing of the Platform infrastructure.

8.2  Despite these measures, no transmission over the internet or electronic storage system is completely secure. jlber cannot guarantee the absolute security of your data. In the event of a personal data breach that poses a risk to your rights and freedoms, jlber will notify the National Privacy Commission within 72 hours of discovery and will communicate directly to affected data subjects as required by the NPC's breach notification rules.

9.1  jlber uses cookies and similar tracking technologies on the Platform to support authentication sessions, remember your preferences, maintain your account security, and analyse Platform usage patterns.

9.2  Types of Cookies Used:

• Strictly Necessary Cookies: Required for the Platform to function. These maintain your login session and protect your account from CSRF attacks. They cannot be disabled without breaking Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, last-played games, and interface layout choices. Disabling these may reduce your Platform experience.
• Analytics Cookies: Collect aggregated, anonymised data on how players navigate the Platform — page visits, session durations, click patterns — to help jlber improve the user experience. Analytics data is not linked to your personal identity.

9.3  jlber does not use third-party advertising cookies or permit third-party ad networks to track your activity across the jlber Platform for the purpose of serving you targeted advertisements on other websites.

9.4  You may control cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to the Platform.

10.1  Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jlber:

• Right to be Informed (Sec. 16(a)): To be told clearly what personal data jlber collects, why, and how it is used — as provided in this Policy;
• Right of Access (Sec. 16(b)): To request a copy of the personal data jlber holds about you, how it was obtained, and its processing purposes;
• Right to Dispute (Sec. 16(c)): To dispute any inaccuracy or error in your personal data, and to have it corrected immediately and continuously;
• Right to Object (Sec. 16(d)): To object to the processing of your personal data, including for direct marketing purposes;
• Right to Erasure or Blocking (Sec. 16(e)): To request the deletion or blocking of your data where it is no longer necessary for the stated purpose, or where processing was unlawful, subject to jlber's legal retention obligations;
• Right to Data Portability (Sec. 18): To receive your personal data in a structured, commonly used, machine-readable format;
• Right to Lodge a Complaint: To file a complaint with the National Privacy Commission of the Philippines (npc.gov.ph) if you believe your data privacy rights have been violated.

10.2  How to Exercise Your Rights. Submit a written data subject request to jlber's Data Protection Officer via live chat support or by emailing the address in Section 14. Include your full name, registered mobile number, and a description of the specific right you wish to exercise. jlber will acknowledge your request within three (3) business days and provide a substantive response within fifteen (15) business days, or within such extended period as permitted by the NPC's rules for complex requests.

10.3  jlber may require identity verification before processing a data subject request to ensure the request comes from the registered account holder and to protect against unauthorised requests.

11.1  The jlber Platform is strictly restricted to persons aged 21 years or older in accordance with PAGCOR's age requirements for casino-style online gaming in the Philippines. jlber does not knowingly collect personal data from individuals under 21 years of age.

11.2  Age verification is conducted during the KYC process. Where jlber identifies that an account has been registered by or on behalf of a person under 21, the account will be immediately suspended, all personal data associated with that account will be deleted as soon as reasonably practicable (subject to any mandatory retention obligations), and any funds will be returned to the depositing payment source after identity verification.

11.3  If you are a parent or guardian and believe that a person under 21 in your care has registered on jlber, please contact our support team immediately via live chat. We take these reports seriously and act on them within 24 hours.

12.1  Some of jlber's service providers — including cloud infrastructure providers and certain game technology vendors — may process or store data in jurisdictions outside the Republic of the Philippines. Where such cross-border transfers occur, jlber ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to the protections required under the Data Privacy Act.

12.2  These safeguards include standard contractual clauses requiring the recipient to maintain data protection standards consistent with Philippine law, and restrictions on further transfers to sub-processors without jlber's prior written authorisation.

12.3  By using the jlber Platform, you consent to the transfer of your personal data to jurisdictions outside the Philippines to the extent necessary to provide the Platform's services, subject to the safeguards described above.

13.1  jlber reserves the right to amend this Privacy Policy at any time in response to changes in applicable law, regulatory guidance from the NPC or PAGCOR, or updates to our data processing practices.

13.2  Where amendments are material — affecting the categories of data collected, the purposes of processing, the parties with whom data is shared, or your data subject rights — jlber will provide at least fourteen (14) days' advance notice to registered players via their registered mobile number or through a prominent Platform notification.

13.3  Non-material changes (such as typographical corrections, clarifications that do not alter the substance of the Policy, or contact detail updates) may take effect immediately upon publication. The "Effective Date" at the top of this Policy will be updated to reflect the date of the most recent revision.

13.4  Your continued use of the jlber Platform following the effective date of a revised Policy constitutes your acceptance of the revised terms. If you disagree with any amendment, you should stop using the Platform and may request account closure in accordance with jlber's Terms and Conditions.

14.1  For any questions, concerns, or requests relating to this Privacy Policy or jlber's data processing activities, please contact jlber's Data Protection Officer:

14.2  If you are not satisfied with jlber's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). The NPC accepts complaints from Philippine data subjects whose privacy rights have been violated. Information on how to file a complaint with the NPC is available on the NPC's official government website.

14.3  jlber is committed to resolving all data privacy enquiries promptly, transparently, and in accordance with the standards set by the Data Privacy Act of 2012 and the National Privacy Commission.