Privacy Policy — ggjl Casino

1. Introduction

1.1 ggjl Casino is committed to protecting the privacy and personal data of all users who interact with our Platform. This Privacy Policy explains, in clear and accessible language, the categories of personal data ggjl processes, the purposes for which it is processed, the legal bases we rely upon, and the rights available to you as a data subject under Philippine law.

1.2 This Privacy Policy applies to all personal data collected through the ggjl website (https://ggjl.club), mobile browser sessions, customer support interactions, and any other touchpoints where ggjl collects personal information from or about you.

1.3 This Privacy Policy should be read alongside ggjl's Terms & Conditions and Responsible Gaming policy, both of which are incorporated by reference.

2. Data Controller

2.1 For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, ggjl Casino is the personal information controller responsible for the personal data processed through this Platform.

2.2 Our designated Data Protection Officer (DPO) can be contacted at:

3. Personal Data We Collect

3.1 ggjl collects personal data only to the extent necessary for the purposes described in this Policy. The categories of data we collect include:

3.1 Registration and Identity Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth
• Philippine mobile number
• Email address
• Username and encrypted password
• Residential address (city/municipality, province, region)

3.2 Identity Verification (KYC) Data

• Government-issued photo ID (PhilSys, UMID, Passport, Driver's License, SSS ID, Voter's ID)
• ID number and expiry date
• Selfie or facial image submitted for liveness verification
• Proof of address where requested

3.3 Financial and Transaction Data

• GCash account number or registered mobile number
• Maya account details
• BPI / BDO / UnionBank account reference numbers (not full account numbers)
• Deposit amounts, dates, and transaction reference numbers
• Withdrawal requests, amounts, and processing status
• Account balance and transaction history

3.4 Gaming Activity Data

• Games played, bet amounts, win/loss outcomes, and session durations
• Game provider and game title
• Bonus and promotional offer usage history
• Responsible gaming limit settings and self-exclusion history

3.5 Technical and Device Data

• IP address and approximate geolocation (city/region level)
• Browser type and version
• Device type, operating system, and screen resolution
• Session timestamps and login history
• Cookies and similar tracking technologies (see Section 10)

3.6 Communications Data

• Customer support chat transcripts
• Email correspondence with ggjl
• Survey responses and feedback submitted voluntarily

3.7 ggjl does not collect sensitive personal information as defined under RA 10173 (such as health data, religious beliefs, or political opinions) unless specifically required by applicable anti-money laundering or responsible gaming regulations in exceptional circumstances.

4. How We Use Your Personal Data

4.1 ggjl uses the personal data we collect for the following purposes:

• Account creation and management: To register your account, authenticate your identity at login, and manage your account settings and preferences on the ggjl Platform.
• KYC and identity verification: To verify your identity, confirm you meet the minimum age requirement of 21 years, and comply with applicable anti-money laundering (AML) regulations.
• Payment processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, UnionBank, Coins.ph, and USDT TRC20, and to maintain accurate financial records.
• Platform operation and game delivery: To provide access to games, calculate and credit winnings, apply bonuses, and maintain the integrity of the gaming environment.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeover attempts, money laundering, and other prohibited conduct.
• Responsible gaming: To monitor gaming behavior for signs of problem gambling, enforce self-exclusion requests and deposit limits, and comply with responsible gaming obligations.
• Customer support: To respond to enquiries, resolve disputes, and provide technical assistance to ggjl account holders.
• Legal and regulatory compliance: To meet obligations under Philippine law including RA 10173 (Data Privacy Act), applicable AML regulations, and requirements of relevant gaming regulators.
• Platform improvement: To analyze usage patterns, improve game selection and platform performance, and develop new features for Filipino players.
• Marketing communications: To send promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time.

5. Legal Basis for Processing

5.1 ggjl processes your personal data on the following legal bases under RA 10173:

• Contract performance: Processing necessary to perform the agreement between you and ggjl (i.e., providing the gaming platform and processing payments).
• Legal obligation: Processing required to comply with applicable Philippine laws including AML regulations, tax reporting, and gaming regulatory requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications, where you have given explicit opt-in consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 ggjl does not sell, rent, or trade your personal data to any third party for their own marketing purposes.

6.2 We may share your personal data with the following categories of third parties only to the extent necessary for the purposes described in this Policy:

• Game providers: Providers such as PG Soft, Pragmatic Play, Jili, Evolution Gaming, and others receive game session data (bet amounts, game outcomes) necessary to operate their games. These providers are contractually bound to process data only for the purpose of game delivery.
• Payment processors: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), and partner banks receive financial transaction data necessary to process deposits and withdrawals. These are licensed Philippine financial institutions subject to BSP regulation.
• KYC and identity verification providers: Third-party identity verification services may process your ID documents and facial images solely for the purpose of age and identity verification.
• IT infrastructure and hosting providers: Cloud hosting and platform infrastructure providers who process data on ggjl's behalf under strict data processing agreements.
• Legal and regulatory authorities: Philippine government agencies, regulators, and law enforcement bodies where disclosure is required by law, court order, or regulatory demand. This includes mandatory reporting obligations under the Anti-Money Laundering Act (AMLA).
• Professional advisors: Legal, audit, and compliance advisors under duties of confidentiality.

6.3 In the event of a corporate transaction (merger, acquisition, or sale of assets), personal data may be transferred to a successor entity subject to equivalent privacy protections.

7. International Data Transfers

7.1 Some of ggjl's technology partners and game providers are located outside the Philippines. Where personal data is transferred internationally, ggjl ensures that appropriate safeguards are in place, including contractual data protection clauses and verification that recipient countries provide an adequate level of data protection.

7.2 If you have questions about the safeguards applied to any specific international transfer of your data, please contact our DPO at [email protected].

8. Data Retention

8.1 ggjl retains personal data for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal and regulatory obligations.

8.2 Specific retention periods:

• Account and identity data: Retained for the lifetime of the account and for five (5) years following account closure, in compliance with Philippine AML record-keeping requirements.
• KYC documents: Retained for five (5) years following account closure or the completion of any related regulatory investigation, whichever is later.
• Financial transaction records: Retained for five (5) years from the date of each transaction, as required by applicable financial regulations.
• Gaming activity logs: Retained for two (2) years from the date of each session.
• Customer support records: Retained for three (3) years from the date of each interaction.
• Marketing consent records: Retained for as long as you are an active subscriber plus two (2) years following opt-out.

8.3 Following the expiry of applicable retention periods, personal data is securely deleted or anonymized so that it can no longer be associated with any individual.

9. Security Measures

9.1 ggjl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• 256-bit TLS/SSL encryption for all data transmitted between your device and the ggjl Platform
• Encryption of sensitive data (passwords, payment details) at rest using industry-standard algorithms
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security audits and penetration testing by independent cybersecurity firms
• Intrusion detection and anomaly monitoring systems operating 24/7
• Automated suspicious login detection with real-time SMS alert to registered Philippine mobile numbers
• Player funds held in accounts segregated from operational company funds
• Regular staff training on data privacy and security obligations

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ggjl will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach and will notify affected individuals without undue delay, in accordance with RA 10173.

10. Cookies and Similar Technologies

10.1 ggjl uses cookies and similar tracking technologies to operate the Platform and improve your user experience. Cookies are small text files stored on your device when you visit the ggjl website.

Types of Cookies Used

• Essential cookies: Strictly necessary for the Platform to function. These include session authentication cookies and security cookies. These cannot be disabled without preventing Platform use.
• Functional cookies: Remember your preferences (language, display settings) to improve your experience on repeat visits.
• Analytics cookies: Collect anonymized or aggregated data about how visitors interact with the Platform, helping ggjl identify areas for improvement. No personally identifiable data is shared with analytics providers.
• Responsible gaming cookies: Store your responsible gaming settings (session timer, reality check preferences) so they persist between visits.

10.2 You can control non-essential cookies through your browser settings. Note that disabling certain cookies may affect Platform functionality. ggjl does not use third-party advertising cookies or behavioral tracking technologies for ad targeting.

11. Your Data Rights

11.1 Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data processed by ggjl:

• Right to be informed: The right to know that your personal data is being collected, processed, and the purposes thereof — as provided in this Privacy Policy.
• Right of access: The right to request a copy of the personal data ggjl holds about you and information about how it is processed.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected. You can update most of your account information directly from Account Settings.
• Right to erasure / right to be forgotten: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to ggjl's legal record-keeping obligations.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
• Right to object: The right to object to processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ggjl has handled your personal data in violation of RA 10173.

11.2 To exercise any of the above rights, contact our DPO at [email protected] with the subject line "Data Privacy Request". We will respond within five (5) business days. Some requests may require identity verification before we can fulfill them.

12. Minors and Age Restriction

12.1 The ggjl Platform is strictly intended for adults aged twenty-one (21) years and above, in accordance with applicable Philippine gaming regulations. ggjl does not knowingly collect personal data from persons under 21 years of age.

12.2 If ggjl becomes aware that personal data has been collected from a person under 21 years of age, such data will be immediately deleted and the account terminated.

12.3 If you believe that a minor has registered on the ggjl Platform, please report this immediately to [email protected].

13. Third-Party Links

13.1 The ggjl Platform does not contain links to third-party websites. However, game providers whose games appear in the ggjl lobby operate under their own privacy practices. Game session data shared with providers is governed by the data processing agreements described in Section 6.

14. Changes to This Privacy Policy

14.1 ggjl may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. The date of the most recent revision is displayed at the top of this page.

14.2 Where changes are material, ggjl will notify registered players via email or via a notice displayed upon login at least seven (7) calendar days before the changes take effect. Continued use of the Platform following the effective date of any update constitutes acceptance of the revised Policy.

15. Contact Us and Data Protection Officer

15.1 For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact ggjl's Data Protection Officer:

15.2 You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe that ggjl has not handled your personal data in accordance with RA 10173 and its implementing regulations.