chatjl Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how chatjl ("chatjl," "we," "us," "our"), the operator of the online gaming platform accessible at chatjl.app, collects, processes, stores, shares, and protects the personal information of users ("you," "your," "the Player") who access or use the chatjl platform.

By registering an account on chatjl.app, accessing the platform as a guest, using any chatjl service, or otherwise interacting with our platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy applies to all personal data collected through chatjl.app, our mobile web interface, any chatjl application, and our customer support channels. It does not apply to third-party websites or services linked from our platform — those services operate under their own privacy policies.

Data Controller

For the purposes of applicable Philippine data privacy law, chatjl is the personal information controller responsible for your personal data collected through chatjl.app. chatjl determines the purposes and means by which your personal information is processed.

chatjl has designated a Data Protection Officer (DPO) who oversees compliance with data privacy obligations. You may contact the DPO directly for any data privacy concerns using the contact details provided in Section 15 of this Policy.

Personal Data We Collect

chatjl collects only the personal data that is necessary to provide you with a secure, compliant, and personalised gaming experience. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name as it appears on a valid government-issued ID
• Date of birth (collected to verify you are 21 years of age or older)
• Residential address, including city and province (e.g., Metro Manila, Cebu, Davao, Quezon City, Makati)
• Nationality and country of residence
• Email address
• Philippine mobile number
• Username and encrypted password

3.2 Identity Verification Documents

• Copies of government-issued photo identification (e.g., PhilSys National ID, SSS ID, UMID, passport, or driver's licence)
• Proof of address documents where required
• Selfie or liveness-check images submitted during KYC verification

3.3 Financial Data

• GCash mobile number and account name associated with transactions
• PayMaya account details associated with transactions
• Bank account name and number for BPI, BDO, or Metrobank transactions
• Transaction history: deposit amounts, withdrawal amounts, dates, and reference numbers
• Source of funds documentation where required for anti-money laundering compliance

3.4 Gaming & Behavioural Data

• Game play history, bet amounts, game outcomes, and session durations
• Bonus redemption history and wagering progress
• Responsible gaming settings such as deposit limits, session time limits, and self-exclusion status
• Customer support interaction records and chat transcripts

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser version
• Session timestamps, login history, and access logs
• Cookie identifiers and similar tracking technologies (see Section 8)

How We Collect Your Data

chatjl collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or respond to a survey or promotion.
• Automatically — through cookies, web beacons, server logs, and similar tracking technologies as you browse and interact with chatjl.app.
• From payment processors — GCash, PayMaya, BPI, BDO, and Metrobank provide transaction confirmation data when you initiate a deposit or withdrawal.
• From identity verification providers — third-party KYC service providers may share the results of identity and document verification checks with chatjl.
• From fraud prevention services — risk management and fraud detection partners may share device fingerprinting and risk-scoring data with chatjl.

How We Use Your Personal Data

chatjl processes your personal data for the following specific purposes:

chatjl does not use your personal data for automated decision-making that produces legal or similarly significant effects without a human review process being available to you upon request.

Legal Basis for Processing

chatjl processes your personal data on one or more of the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Contractual necessity — processing is necessary to perform the contract between you and chatjl (i.e., to provide you with gaming and payment services as a registered player).
• Legal obligation — processing is required for chatjl to comply with Philippine law, including anti-money laundering obligations, PAGCOR-aligned regulatory requirements, and tax reporting.
• Legitimate interests — processing is necessary for chatjl's legitimate interests in fraud prevention, platform security, and responsible gaming enforcement, provided these interests are not overridden by your privacy rights.
• Consent — for certain processing activities such as sending promotional emails or SMS, chatjl relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

Sharing Your Personal Data

chatjl does not sell or rent your personal data to any third party. We share your data only in the following circumstances and only to the extent necessary:

7.1 Service Providers

chatjl engages trusted third-party service providers who process data on our behalf under strict data processing agreements. These include:

• Payment processors — GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers — to verify that you are who you say you are and that you meet the 21+ age requirement.
• Game providers — including JILI and other licensed providers, who receive anonymised session data required to deliver game content.
• Fraud prevention and risk management partners — to protect chatjl and its players from fraudulent activity.
• Cloud infrastructure providers — who host chatjl's platform and data under secure, contractually mandated conditions.

7.2 Legal and Regulatory Disclosures

chatjl may disclose your personal data to Philippine government authorities, law enforcement agencies, regulatory bodies, or courts where required or permitted by law, including but not limited to the Anti-Money Laundering Council (AMLC), PAGCOR, the National Privacy Commission, and the Bureau of Internal Revenue (BIR).

7.3 Business Transfers

In the event that chatjl undergoes a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and your rights will be protected throughout.

Cookies & Tracking Technologies

chatjl uses cookies and similar tracking technologies on chatjl.app to provide essential functionality, enhance your experience, and support platform security. The following categories of cookies are used:

• Strictly necessary cookies — required for the platform to function. These include session authentication cookies that keep you logged in and security tokens that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies — remember your preferences such as language, currency display, and responsible gaming settings between sessions.
• Analytics cookies — help chatjl understand how players navigate the platform so we can identify areas for improvement. Data collected by analytics cookies is aggregated and does not identify you individually.
• Security and fraud-prevention cookies — assist chatjl in detecting suspicious activity such as account takeover attempts and coordinated bonus abuse.

chatjl does not use third-party advertising cookies or tracking pixels that share your data with external marketing platforms.

You may manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of chatjl.app. For details on how to manage cookies in your browser, consult your browser's help documentation.

Data Retention

chatjl retains your personal data for no longer than is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where deletion is not immediately technically feasible (for example, in backup storage), chatjl isolates the data from active processing until it can be securely destroyed.

Security Measures

chatjl implements a layered set of technical, organisational, and procedural security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include, but are not limited to:

• Transport security: All data in transit between your device and chatjl.app is encrypted using TLS 1.2 or higher (256-bit SSL).
• Data at rest encryption: Sensitive personal data, including identity documents and financial data, is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorised chatjl personnel on a strict need-to-know basis. All access is logged and subject to regular review.
• Two-factor authentication: chatjl strongly recommends enabling 2FA on your account via SMS to your registered Philippine mobile number. Internal chatjl systems require 2FA for all staff accessing production data.
• Penetration testing and vulnerability scanning: chatjl conducts regular security assessments of its platform infrastructure.
• Staff training: All chatjl personnel with access to personal data receive regular data privacy and security training.
• Incident response: chatjl maintains a documented data breach response procedure aligned with NPC notification requirements.

Your Data Subject Rights

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

• Right to be informed — you have the right to be informed about what personal data chatjl collects, how it is used, and with whom it is shared. This Policy fulfils that obligation.
• Right of access — you have the right to request a copy of the personal data chatjl holds about you, together with information about how that data is being processed.
• Right to rectification — you have the right to request correction of inaccurate or incomplete personal data held about you. For basic account details, you may update these directly in your chatjl account settings.
• Right to erasure — you have 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 chatjl's legal obligations to retain certain data (see Section 9).
• Right to data portability — you have the right to receive a structured, machine-readable copy of personal data you have provided to chatjl for the purpose of transmitting it to another controller.
• Right to object — you have the right to object to processing based on legitimate interests, including profiling. You also have the right to withdraw marketing consent at any time.
• Right to file a complaint — if you believe chatjl has violated your data privacy rights, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact chatjl's Data Protection Officer using the contact details in Section 15. chatjl will respond to all data subject rights requests within 15 working days of receipt, in accordance with NPC guidelines. We may request proof of identity before processing your request.

Minors & Age Requirement

chatjl does not knowingly collect personal data from persons under the age of 21 years. The chatjl platform is intended exclusively for adults aged 21 and above in accordance with PAGCOR-aligned gaming regulations applicable in the Philippines.

If chatjl discovers that personal data has been collected from a person under the age of 21, we will immediately close that account, delete the associated personal data, and refund any real-money balance to the payment method used for deposit, subject to identity and ownership verification.

Parents or guardians who believe that their child may have registered a chatjl account are encouraged to contact our support team immediately via live chat or email so the account can be investigated and closed without delay.

Cross-Border Data Transfers

In certain circumstances, your personal data may be transferred to or accessed by recipients located outside the Philippines — for example, where chatjl uses cloud infrastructure providers or game content providers whose servers are located in other countries.

Where such transfers occur, chatjl ensures that appropriate safeguards are in place to protect your personal data at a standard at least equivalent to that required under the Philippine Data Privacy Act. These safeguards may include:

• Standard contractual clauses included in data processing agreements with third-party providers.
• Processing only by providers in jurisdictions that have been assessed as providing an adequate level of data protection.
• Binding corporate rules or equivalent organisational data protection policies where the recipient is part of a corporate group.

You may request further information about the specific safeguards applicable to any cross-border transfer of your data by contacting chatjl's Data Protection Officer.

Changes to This Privacy Policy

chatjl may update this Privacy Policy from time to time to reflect changes in our data processing practices, changes in applicable law, or improvements to the chatjl platform. When we make material changes to this Policy, we will:

• Update the "Last Updated" date displayed at the top of this page.
• Post a prominent notice on the chatjl.app homepage or within the player account dashboard for a period of not less than 30 days following the change.
• Where required by law, seek your fresh consent before processing your data under the revised terms.

We recommend that you review this Privacy Policy periodically. Your continued use of the chatjl platform following the effective date of any changes constitutes your acceptance of the updated Policy.

Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way chatjl processes your personal data, you may contact our Data Protection Officer or general support team through the following channels:

• Data Protection Officer (DPO): [email protected] — please include "Privacy / DPO Request" in the subject line of your message.
• Live Chat Support: Available 24/7 via the live chat widget on chatjl.app — suitable for general privacy queries and account-level data requests.
• Response Time: chatjl acknowledges all privacy-related correspondence within 48 hours and provides a substantive response within 15 working days.

If you are not satisfied with chatjl's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing the Philippine Data Privacy Act.