jlhp Privacy Policy

1 Introduction

jlhp ("the Platform," "we," "us," "our") operates the online gaming platform accessible at jlhp.cam and its associated mobile-optimized interfaces. In the course of providing our services to registered players in the Philippines, jlhp collects and processes personal data as described in this Privacy Policy ("Policy").

This Policy is issued in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines. Where applicable, jlhp also observes principles consistent with internationally recognized data protection standards.

jlhp acts as the personal information controller in respect of your data. This means we determine the purposes and means by which your personal data is processed. Where we engage third-party service providers who process data on our behalf, they act as personal information processors under binding contractual arrangements that restrict their use of your data to the services they provide to jlhp.

This Policy should be read together with the jlhp Terms & Conditions and Responsible Gaming Policy, which are available on the jlhp platform. In the event of a conflict between this Policy and the Terms & Conditions on a privacy-related matter, this Policy shall prevail.

2 Personal Data We Collect

jlhp collects the following categories of personal data in connection with your account and use of the Platform:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (used to verify the 21+ age requirement)
• Residential address, city, and province within the Philippines
• Email address and mobile phone number
• Username chosen during registration

2.2 Identity Verification (KYC) Data

• Copy or photograph of a valid Philippine government-issued ID (driver's license, UMID, SSS ID, PhilHealth ID, PRC ID, Voter's ID, or Philippine passport)
• Selfie or proof-of-life image, where required by our KYC provider for enhanced verification
• Additional documentary proof of address if requested during enhanced due diligence

2.3 Financial & Transaction Data

• Deposit and withdrawal history, including amounts, timestamps, and payment methods used
• GCash account number, Maya wallet ID, bank account details, or other payment identifiers linked to your account
• Tokenized payment card data where Visa or Mastercard is used (full card numbers are not stored by jlhp)
• Cryptocurrency wallet addresses where USDT TRC20 is used

2.4 Gaming Activity Data

• Game session logs, including game titles played, bet amounts, win/loss outcomes, and session durations
• Bonus activation, wagering progress, and promotion participation records
• Responsible gaming tool settings, including any deposit limits, loss limits, or self-exclusion periods applied to your account

2.5 Technical & Usage Data

• IP address and geolocation data at the time of login and during active sessions
• Device type, operating system, browser type and version
• Session duration, pages viewed, navigation paths, and feature interactions
• Login timestamps, failed login attempts, and security event logs

2.6 Communications Data

• Content of live chat, email, and support ticket communications with the jlhp customer support team
• Records of promotional communications sent to you and your response or opt-out actions

3 How We Collect Your Data

jlhp collects personal data through the following channels:

• Account Registration: When you create a jlhp account, you provide your name, date of birth, contact details, and chosen credentials directly through the registration form.
• KYC Submission: When you submit identity verification documents in response to a KYC request, either during registration or prior to processing your first withdrawal.
• Deposits & Withdrawals: When you initiate a payment transaction, your chosen payment method provider shares transaction confirmation data with jlhp.
• Platform Use: Technical and gaming activity data is collected automatically as you navigate and interact with the jlhp platform through server logs, session tracking, and analytics tools.
• Customer Support: When you contact jlhp Support via live chat, email, or any other channel, the content of your communication is recorded and stored.
• Cookies & Tracking Technologies: As described in Section 7, certain data is collected automatically through cookies and similar technologies when you visit jlhp.cam.

4 Legal Bases for Processing

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

5 How We Use Your Data

jlhp uses your personal data for the following purposes:

5.1 Account & Service Delivery

To create and maintain your jlhp account; to verify your identity and age eligibility; to process deposits, withdrawals, and bonus credits; to record game sessions and maintain an accurate transaction history; and to provide access to all games and features available on the Platform.

5.2 Security & Fraud Prevention

To detect and prevent unauthorized access to your account; to identify suspicious betting patterns or transaction behavior that may indicate fraud, collusion, or money laundering; to investigate security incidents; and to enforce the jlhp one-account-per-player policy. Login location data and device fingerprinting are used specifically for this purpose.

5.3 Regulatory Compliance

To fulfill jlhp's obligations under Philippine gaming regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act. This includes maintaining records of player transactions and KYC documents for the mandatory minimum retention periods, and reporting to relevant authorities such as PAGCOR and the Anti-Money Laundering Council (AMLC) where legally required.

5.4 Responsible Gaming

To monitor gaming patterns that may indicate problem gambling behavior; to apply player-requested account restrictions such as deposit limits and self-exclusion; to display session time alerts and reality check prompts; and to send welfare-related communications to players identified as potentially at risk.

5.5 Customer Support

To respond to your support enquiries, resolve disputes, process complaints, and maintain a record of support interactions for quality assurance and training purposes.

5.6 Marketing & Promotions

Where you have provided consent, to send you information about jlhp promotions, bonuses, new game releases, and other offers that may be relevant to you. You may withdraw marketing consent at any time by contacting jlhp Support or by using the unsubscribe mechanism in any promotional email you receive.

5.7 Platform Improvement

To analyze aggregate, anonymized usage data to understand how players interact with the jlhp platform; to identify technical issues; and to guide product development decisions. This analysis is performed on anonymized or pseudonymized datasets where individual identification is not required.

6 Sharing Your Personal Data

jlhp does not sell, rent, or trade your personal data to any third party. Your data may be shared with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Processors: GCash, Maya, Visa/Mastercard network partners, BPI, BDO, Metrobank, UnionBank, 7-Eleven payment networks, Coins.ph, and cryptocurrency processing partners — to facilitate your deposit and withdrawal transactions.
• KYC & Identity Verification Providers: Licensed third-party identity verification services that process your submitted ID documents and biometric data to confirm your identity and age on jlhp's behalf.
• Game Providers: Certified game studios and live casino operators whose games are hosted on jlhp. These providers may receive session data (player identifier, bet amounts, game outcomes) necessary to operate their games within jlhp's platform environment.
• IT Infrastructure & Security Providers: Cloud hosting, content delivery, fraud detection, and cybersecurity service providers who maintain jlhp's technical infrastructure under strict data processing agreements.
• Regulatory & Law Enforcement Authorities: Philippine government agencies including PAGCOR, the AMLC, the NPC, and law enforcement bodies where jlhp is legally obligated to disclose data or where disclosure is necessary to protect the safety of players or the public.
• Professional Advisors: Legal counsel, auditors, and compliance consultants who are bound by professional confidentiality obligations.

7 Cookies & Tracking Technologies

jlhp uses cookies, web beacons, and similar tracking technologies on jlhp.cam. A cookie is a small text file placed on your device by the jlhp website when you visit. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function correctly. These include session authentication cookies that keep you logged in, security tokens, and load-balancing cookies. These cannot be disabled without preventing you from using the Platform.
• Functional Cookies: Remember your preferences — such as your preferred language, display settings, and game lobby filters — so you do not need to reset them on each visit.
• Analytics Cookies: Used to collect aggregate data about how visitors navigate and use jlhp.cam — pages visited, session durations, and feature interactions. This data is processed in anonymized or pseudonymized form for platform improvement purposes.
• Security Cookies: Support jlhp's fraud detection systems by tracking login patterns and flagging anomalous access attempts.

You can manage non-essential cookies through your browser settings. Note that disabling functional cookies may affect your experience on jlhp — for example, your preferences may not be saved between sessions.

8 Data Security

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

• Transport Layer Security: All data transmitted between your device and jlhp's servers is encrypted using TLS 1.2 or higher (equivalent to 256-bit SSL encryption).
• Password Hashing: Account passwords are stored as cryptographic hashes using industry-standard algorithms. jlhp staff cannot read or recover plain-text passwords.
• Payment Tokenization: Payment card details are tokenized by our payment processor partners. Full card numbers are never stored on jlhp's servers.
• Access Controls: Access to personal data within jlhp's systems is restricted on a strict need-to-know basis. Staff are granted access only to the data necessary to perform their specific role.
• Regular Security Testing: jlhp conducts periodic vulnerability assessments and penetration testing of its platform infrastructure.
• Incident Response: jlhp maintains a data breach response plan. In the event of a breach that poses a risk to your rights, jlhp will notify affected players and the National Privacy Commission within the timeframes required by law.

While jlhp uses commercially reasonable technical and organizational measures to protect your data, no online system can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for ensuring that your device is protected with up-to-date security software.

9 Data Retention

jlhp retains your personal data for as long as your account remains active and for a minimum period following account closure as required by law. The key retention periods are as follows:

• Account & Identity Data: Retained for a minimum of five (5) years following account closure, in compliance with applicable gaming regulatory requirements and anti-money laundering laws.
• Transaction Records: Retained for a minimum of five (5) years following the date of the transaction, in line with AMLC record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the end of the business relationship.
• Customer Support Communications: Retained for three (3) years following the resolution of a support interaction, unless the communication is relevant to an ongoing legal or regulatory matter.
• Gaming Activity Logs: Retained for three (3) years following the relevant gaming session, or longer where required for dispute resolution or regulatory inspection.
• Security & Access Logs: Retained for twelve (12) months on a rolling basis for fraud detection and incident investigation purposes.

Following the expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymized, unless retention for a longer period is required by law or necessary for the establishment, exercise, or defense of legal claims.

10 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by jlhp:

• Right to be Informed: The right to be told what personal data jlhp holds about you, why it is collected, and how it is used — as set out in this Policy.
• Right of Access: The right to request a copy of the personal data jlhp holds about you, together with information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by jlhp about you.
• 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 jlhp's legal and regulatory retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to request its transmission to another data controller where technically feasible.
• Right to Object: The right to object to processing of your personal data where jlhp relies on legitimate interests as the legal basis, including direct marketing communications.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jlhp has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact jlhp's Data Protection Officer using the contact details in Section 14. jlhp will acknowledge your request within five (5) business days and respond fully within fifteen (15) business days. Where a request requires additional time to process, jlhp will notify you of the extended timeframe and the reason for it.

11 Children's Privacy

jlhp is strictly an adults-only platform. Registration and use of jlhp is limited to individuals who are at least 21 years of age, in compliance with applicable Philippine gaming regulations. jlhp does not knowingly collect personal data from individuals under the age of 21.

If jlhp discovers or is notified that an account has been created by or is being used by an individual under 21 years of age, that account will be immediately suspended, the relevant personal data will be deleted, and any funds associated with the account will be handled in accordance with applicable regulatory requirements.

Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gaming platforms, including jlhp. If you believe a minor may have registered on jlhp using false age information, please contact jlhp Support immediately.

12 International Data Transfers

jlhp's primary data infrastructure is hosted on servers located within or accessible from the Asia-Pacific region. In the course of providing its services, jlhp may engage third-party service providers — including game studios, payment processors, and technology vendors — whose servers are located outside the Philippines.

Where personal data is transferred outside the Philippines, jlhp will ensure that appropriate safeguards are in place to protect your data in accordance with the standards required by the Data Privacy Act of 2012 and the National Privacy Commission's guidelines on cross-border data transfers. These safeguards may include contractual data processing agreements that impose obligations on recipients equivalent to those applicable under Philippine law.

jlhp will not transfer your data to jurisdictions that do not provide an adequate level of data protection unless the transfer is covered by appropriate contractual safeguards or falls within a recognized exception under the Data Privacy Act.

13 Changes to This Privacy Policy

jlhp reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, updates to applicable laws, or improvements to the jlhp platform. When material changes are made to this Policy, jlhp will notify registered players via email to the address on file and by displaying a prominent notice on the jlhp Platform at least seven (7) days before the amended Policy takes effect.

Your continued use of the jlhp Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you must stop using the Platform and may close your account in accordance with the jlhp Terms & Conditions.

The version of this Policy most recently published at jlhp.cam/privacy-policy shall be the authoritative version. Archived prior versions are available from jlhp Support on request.

14 Contact & Data Protection Officer

If you have questions, concerns, or requests relating to this Privacy Policy or jlhp's handling of your personal data, please contact our Data Protection Officer (DPO) through the following channels:

Please include your registered username, a clear description of your request or concern, and any relevant account or transaction reference numbers when contacting us to help us assist you as efficiently as possible.

If you are not satisfied with jlhp's response to your data privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available on the Commission's official channels.