90jl Privacy Policy

1. Introduction

90jl ("we," "us," or "our") operates the online gaming platform at https://90jl.biz (the "Platform"). We act as the Personal Information Controller ("PIC") in respect of personal data collected from players, prospective players, and visitors to the Platform.

This Privacy Policy ("Policy") describes our practices regarding the collection, processing, storage, disclosure, and protection of personal data in connection with your use of the Platform and our Services. It also describes your rights as a data subject under the Philippine Data Privacy Act of 2012 ("DPA") and how to exercise those rights.

By registering an account or using the Platform, you acknowledge that you have read and understood this Policy. This Policy should be read together with our Terms & Conditions, which govern your use of the Platform.

2. Data Controller Information

The Personal Information Controller responsible for your data is 90jl, operating at https://90jl.biz. For data privacy inquiries or to exercise your data subject rights, you may contact our Data Protection Officer (DPO) using the contact information provided in Section 15 of this Policy.

90jl operates within the regulatory framework established by the Philippine Amusement and Gaming Corporation ("PAGCOR") and processes personal data in accordance with the requirements of PAGCOR's licensing conditions, which include obligations relating to anti-money laundering (AML) compliance, Know Your Customer (KYC) procedures, and responsible gaming measures.

3. Personal Data We Collect

90jl collects personal data through various means, including direct registration, your use of the Platform, and automatic technical collection. The categories of personal data we collect are set out in the table below:

3.1 Sensitive Personal Information

In connection with responsible gaming obligations, 90jl may process data relating to self-exclusion status and problem gambling indicators. This data is treated as sensitive personal information under the DPA and is subject to heightened protection measures. It is processed exclusively for the purposes of player welfare and regulatory compliance.

3.2 Data Not Collected

90jl does not collect full payment card numbers (we use tokenized payment processing where card payments are applicable). We do not collect biometric data beyond identity photograph for KYC purposes, and we do not collect information about minors, as the Platform is restricted to persons aged 21 and above.

4. How We Use Your Personal Data

90jl uses your personal data only for the purposes set out below. We do not use your data for automated decision-making that produces legal or similarly significant effects without human review.

• Account Administration: Creating and managing your 90jl account, verifying your identity, processing login authentication, and maintaining accurate account records.
• Service Delivery: Enabling access to games, processing bets, calculating and crediting winnings, and operating the features of the Platform.
• Payment Processing: Processing deposits and withdrawals via GCash, PayMaya, BDO, BPI, Metrobank, 7-Eleven, Cebuana, and USDT; reconciling transactions; and maintaining financial records.
• KYC & AML Compliance: Verifying player identity prior to withdrawal; screening against sanctions lists and AML watchlists as required by PAGCOR and Philippine AMLC regulations.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, bonus abuse, and multi-accounting.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behavior; enforcing deposit limits, self-exclusions, and cooling-off periods elected by players.
• Customer Support: Responding to queries, resolving disputes, and maintaining records of support interactions for quality assurance.
• Legal Compliance: Complying with PAGCOR licensing conditions, AMLC reporting obligations, tax reporting requirements under Philippine law, and any court orders or lawful requests from competent authorities.
• Marketing Communications (with consent): Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive marketing communications. You may withdraw consent at any time through your account notification settings.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the performance, design, and content of the Platform.

5. Legal Basis for Processing

90jl processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary for the performance of our Terms & Conditions with you — including account management, game operation, and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AML/AMLC reporting obligations, and other applicable Philippine laws and regulations.
• Legitimate Interests: Processing for fraud prevention, account security, responsible gaming monitoring, and platform analytics — where these interests do not override your rights and freedoms.
• Consent: Processing for marketing communications, where you have provided explicit, informed, and freely given consent. Consent may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.

6. Data Sharing & Disclosure

90jl does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your personal data only in the following limited circumstances:

6.1 Service Providers (Personal Information Processors)

We engage trusted third-party service providers who process personal data on our behalf under binding data processing agreements. These include payment processors (GCash, PayMaya, BDO, BPI, and other payment partners), KYC/identity verification service providers, cloud hosting infrastructure providers, customer support platform providers, and fraud detection and AML screening services.

6.2 Regulatory Authorities

We are required to disclose certain player data to PAGCOR as a condition of our operating license, and to the Anti-Money Laundering Council ("AMLC") where transactions meet reportable thresholds under the Anti-Money Laundering Act. We may also disclose data in response to lawful orders from Philippine courts, the National Privacy Commission ("NPC"), law enforcement agencies, or other competent government bodies.

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or other corporate restructuring, your personal data may be transferred to a successor entity. You will be notified of any such transfer and the privacy implications at least 30 days in advance.

7. Cookies & Tracking Technologies

The 90jl Platform uses cookies and similar tracking technologies to provide and improve our Services. Cookies are small text files stored on your device when you visit the Platform.

7.1 Types of Cookies Used

• Essential Cookies: Required for the Platform to function — including session authentication, security tokens, and load balancing. These cannot be disabled without impairing functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and last-played game categories.
• Analytics Cookies: Collect anonymised data about how players use the Platform (page visits, session duration, navigation paths) to improve user experience. Data is aggregated and not linked to individual identities.
• Security Cookies: Used for fraud detection and to identify suspicious login patterns or device anomalies.

You may manage or disable non-essential cookies through your browser settings. Disabling essential cookies will impair your ability to log in and use the Platform. 90jl does not use third-party advertising cookies or behavioral tracking cookies for advertising purposes.

8. Data Retention

90jl retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by applicable law:

• Account and KYC Data: Retained for a minimum of 5 years from account closure, as required by PAGCOR and AMLC regulations.
• Financial Transaction Data: Retained for a minimum of 5 years from the date of each transaction, in compliance with Philippine AML record-keeping requirements.
• Gaming Session Logs: Retained for a minimum of 3 years from the date of each session.
• Customer Support Records: Retained for 3 years from the date of each interaction.
• Marketing Consent Records: Retained for the duration of consent plus 3 years to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Where data is required for ongoing legal proceedings or regulatory investigations, retention may be extended until the matter is resolved.

9. Data Security Measures

90jl implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 90jl Platform.
• Encryption at rest for sensitive personal data stored on 90jl servers.
• Access controls limiting employee access to personal data on a strict need-to-know basis.
• Two-factor authentication requirements for staff accessing systems containing personal data.
• Regular security audits and penetration testing of the Platform infrastructure.
• Incident response procedures for detecting, investigating, and notifying affected individuals and the NPC of personal data breaches within the timeframes prescribed by the DPA.

While 90jl employs robust security measures, no system is completely immune to security threats. You are encouraged to take personal responsibility for your account security by using a strong password and enabling 2FA.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 90jl:

• Right to Be Informed: The right to be informed of the collection and processing of your personal data — which this Policy fulfils.
• Right of Access: The right to request a copy of the personal data 90jl holds about you, and information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most data directly in your account settings.
• Right to Erasure ("Right to Be Forgotten"): The right to request deletion of your personal data, subject to 90jl's legal obligations to retain certain data under PAGCOR and AML regulations. Deletion requests cannot be honoured where retention is legally required.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to Object: The right to object to the processing of your personal data for marketing purposes. You may withdraw consent for marketing at any time through your account notification settings.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your personal data has been processed in violation of the DPA. NPC contact details are available at privacy.gov.ph.

To exercise any of the above rights, please contact our DPO using the contact details in Section 15. We will respond to all verified requests within 15 business days.

11. Children's Privacy

The 90jl Platform is strictly intended for persons aged 21 years and above. 90jl does not knowingly collect, process, or store personal data from persons under 21. If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and you believe your child (under 21) has provided personal data to 90jl, please contact our DPO immediately using the details in Section 15.

12. Third-Party Links

The 90jl Platform may contain links to other websites operated by third parties, including payment partner pages. This Privacy Policy applies only to the 90jl Platform. 90jl is not responsible for the privacy practices of third-party websites. We recommend reviewing the privacy policy of any third-party website you visit.

13. International Data Transfers

90jl's primary operations and data storage are based within the Philippines. Where it is necessary to transfer personal data to service providers located outside the Philippines (for example, cloud infrastructure providers), 90jl ensures that such transfers are subject to appropriate safeguards, including contractual clauses that provide equivalent data protection standards to those required under the Philippine DPA.

We do not transfer personal data to countries whose data protection laws do not provide an adequate level of protection without implementing appropriate safeguards as required by the NPC.

14. Amendments to This Policy

90jl may update this Privacy Policy from time to time to reflect changes in our processing activities, applicable law, or PAGCOR regulatory requirements. When we make material changes that significantly affect your rights, we will notify you by email or through a prominent notice on the Platform at least 7 days before the change takes effect.

The "Last Updated" date at the top of this Policy will always reflect the most recent revision. We encourage you to review this Policy periodically. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Policy.

15. Contact Our Data Protection Officer

For all data privacy queries, requests to exercise your data subject rights, or to report a potential data privacy concern, please contact 90jl's Data Protection Officer:

• Email: [email protected] (plain text — not a link; subject line: "Data Privacy Request")
• Live Chat: Available 24/7 on the 90jl Platform. Mention "data privacy" and you will be connected to the DPO support queue.

We will acknowledge all data subject requests within 3 business days and aim to resolve them fully within 15 business days. If your request involves complex matters requiring legal review, we will notify you of any extension of the response timeline.