Data Protection
At jll16, we take your privacy seriously. This Privacy Policy explains exactly what personal information we collect, why we collect it, how we use and protect it, and what rights you hold over your own data under Philippine law.
We only collect data necessary for platform operation and regulatory compliance.
All personal data is stored with 256-bit SSL encryption and access controls.
jll16 does not sell, rent, or trade your personal information to third parties.
You retain the right to access, correct, and delete your data under RA 10173.
Data is kept only for as long as required by law or legitimate platform purposes.
Full compliance with the Philippine Data Privacy Act and its implementing rules.
Your privacy matters to jll16.
This Privacy Policy is issued by jll16 and governs the collection, use, processing, and storage of personal data in connection with the jll16 gaming platform. This Policy is compliant with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations. By registering a jll16 account and using the Platform, you acknowledge that you have read and understood this Privacy Policy.
For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, jll16 is the Personal Information Controller in respect of all personal data collected from registered users and visitors of the jll16 platform at jll16.vip.
As the Personal Information Controller, jll16 determines the purposes for which, and the manner in which, personal data is processed. jll16 is responsible for implementing appropriate organizational and technical security measures to protect your personal information against accidental or unlawful destruction, alteration, unauthorized disclosure, and any other unlawful processing.
You may contact jll16's Data Protection team at any time in relation to this Policy. Contact details are set out in Section 13.
jll16 collects the following categories of personal data from users of the Platform:
We do not collect: Full payment card numbers, CVV codes, GCash PINs, or online banking passwords. These are never transmitted to or stored by jll16.
jll16 collects personal data through the following means:
jll16 processes your personal data for the following purposes and on the following legal bases under the Data Privacy Act of 2012:
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Account registration and management | Identity, contact, account data | Contractual necessity |
| Age and identity verification (KYC) | Identity documents, date of birth | Legal obligation (PAGCOR / AML) |
| Processing deposits and withdrawals | Financial, identity data | Contractual necessity |
| Anti-money laundering compliance | Financial, identity, transaction data | Legal obligation (RA 9160) |
| Fraud prevention and security | Technical, financial, identity data | Legitimate interest / legal obligation |
| Customer support and complaint handling | Communication, account data | Contractual necessity |
| Responsible gaming monitoring | Gameplay, account, financial data | Legal obligation / legitimate interest |
| Loyalty program and promotions | Account, gameplay data | Consent / contractual necessity |
| Platform analytics and improvement | Technical, usage data (anonymized) | Legitimate interest |
| Marketing communications (opt-in only) | Contact, preference data | Consent |
jll16 does not process your personal data for purposes other than those listed above. Where processing is based on consent, you retain the right to withdraw consent at any time, which will not affect the lawfulness of processing carried out prior to withdrawal.
jll16 does not sell, rent, or trade your personal data to any third party for commercial purposes. Your data is shared only in the following strictly controlled circumstances:
jll16 engages third-party service providers who process personal data on our behalf under written data processing agreements that bind them to strict confidentiality and security obligations. These include KYC and identity verification providers, payment processing facilitators (GCash, PayMaya, banking partners), fraud detection and cyber-security services, and cloud infrastructure providers.
jll16 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or courts of competent jurisdiction where required by applicable Philippine law, lawful court order, or regulatory instruction. jll16 will, where legally permissible, notify affected users of such disclosures.
In the event of a merger, acquisition, or sale of all or substantially all of jll16's assets, personal data held by jll16 may be transferred to the acquiring entity, subject to the same or equivalent data protection obligations. Affected users will be notified in advance of such transfer wherever practicable.
Confirmation: jll16 does not share your data with advertisers, data brokers, social media networks, or any entity for the purpose of targeted advertising or data monetization.
jll16 primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data to servers or service providers located outside the Philippines — for example, in connection with cloud infrastructure or third-party technology services — jll16 ensures that such transfers are made in compliance with the Data Privacy Act of 2012 and its Implementing Rules.
International transfers are conducted only: (a) to countries recognized by the National Privacy Commission as providing an adequate level of data protection; (b) subject to appropriate contractual safeguards, including Standard Contractual Clauses or equivalent data processing agreements; or (c) where the transfer is necessary for the performance of the contract between jll16 and the data subject.
jll16 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following retention schedule applies:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of account + 5 years post-closure | Legal obligation (AML, gaming regulations) |
| KYC identity documents | 5 years from date of verification | AMLC / PAGCOR regulatory requirement |
| Financial transaction records | 5 years from transaction date | RA 9160 Anti-Money Laundering Act |
| Customer support communications | 3 years from last interaction | Contractual / legitimate interest |
| Technical / log data | 12 months from collection | Security and fraud prevention |
| Marketing preference data | Until consent is withdrawn or account is closed | Consent-based |
Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized in accordance with jll16's data disposal procedures.
jll16 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:
Data Breach Notification: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jll16 will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, in accordance with the Data Privacy Act of 2012.
jll16 uses cookies and similar tracking technologies to operate the Platform, maintain session continuity, prevent fraud, and analyze user behavior in aggregate. Cookies are small text files stored on your device. The following categories of cookies are used:
You may manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will impair or prevent access to the Platform. jll16 does not deploy advertising cookies or share behavioral data with advertising networks.
Under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, you hold the following rights in relation to your personal data held by jll16. These rights may be exercised by contacting the jll16 Data Protection team as described in Section 13.
jll16 will respond to all data subject rights requests within 30 calendar days of receipt. Where a request is complex or involves a large volume of data, jll16 may extend this period by a further 30 days with prior written notice to the requesting data subject.
Note that certain rights are subject to legal limitations. For example, jll16 is required by law to retain certain transaction and identity records for anti-money laundering compliance purposes, which may limit erasure requests in respect of those records.
The jll16 Platform is strictly intended for use by individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. jll16 does not knowingly collect, process, or retain personal data from individuals below the age of 21.
Age verification is conducted as part of the account registration and KYC process. Any account found to belong to an individual under the age of 21 will be immediately closed, all associated data will be securely deleted (subject to any applicable legal retention obligations), and any funds held will be returned via the registered payment method after completion of applicable checks.
If you believe that a person under 21 has provided personal data to jll16, please contact us immediately at the details in Section 13, and we will take prompt action to investigate and, where confirmed, remove the data.
jll16 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, platform functionality, or data processing practices. All updates will be published on this page with a revised effective date.
Where changes are material — meaning they significantly affect your rights or the way in which jll16 processes your personal data — we will provide advance notice to registered account holders via in-platform notification or email to your registered address, with a minimum of 14 days before the updated Policy takes effect.
We encourage you to review this Privacy Policy periodically. Your continued use of the jll16 Platform following the effective date of any update constitutes your acknowledgment of the revised Policy.
For any questions, concerns, or requests relating to this Privacy Policy or your personal data rights, please contact the jll16 Data Protection team through the following channels:
If you are unsatisfied with jll16's response to a data subject rights request, you have the right to escalate a complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.
Related Documents: Terms & Conditions · Responsible Gaming Policy · FAQ
This Privacy Policy was last updated: January 1, 2026. This version supersedes all prior versions.
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