Privacy Policy

1 Introduction

19jl ("we," "us," or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the 19jl Platform at https://19jl.app (the "Platform"), including its mobile application and all associated services.

This Privacy Policy ("Policy") describes how 19jl collects, uses, stores, shares, and protects your personal data. It also explains the rights available to you as a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its implementing rules and regulations.

By registering an account on 19jl or otherwise using the 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 forms part of and should be read together with our Terms & Conditions.

If you do not agree with this Policy, please do not use the Platform or provide us with any personal data.

2 Data Controller

19jl acts as the personal information controller ("PIC") in respect of the personal data collected through the Platform. As PIC, 19jl determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data privacy law.

Where 19jl engages third-party service providers to process personal data on its behalf (for example, payment processors or identity verification providers), those parties act as personal information processors ("PIP") and are contractually bound to process data only in accordance with 19jl's instructions and applicable law.

3 Data We Collect

19jl collects the following categories of personal data, depending on how you interact with the Platform:

We do not intentionally collect sensitive personal information (as defined under the DPA) unless it is strictly necessary for identity verification or regulatory compliance purposes, in which case we will seek your explicit consent and handle such data with heightened care.

4 How We Collect Data

19jl collects your personal data through the following means:

• Direct interactions — when you register an account, complete identity verification, make a deposit or withdrawal, contact our support team, or participate in a promotion.
• Automated technologies — when you browse or use the Platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources — we may receive data about you from identity verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), fraud prevention services, and analytics partners, where permitted by law.
• Publicly available sources — in limited circumstances, we may collect data from publicly available sources to verify information you have provided or to comply with anti-money laundering obligations.

5 How We Use Your Data

19jl processes your personal data for the following purposes:

• Account creation and management — to register your account, verify your identity and age, and maintain your player profile.
• Service delivery — to provide access to games, process deposits and withdrawals, and administer bonuses and promotions.
• Legal and regulatory compliance — to meet our obligations under Philippine gaming regulations, anti-money laundering laws, and data privacy law, including reporting to relevant authorities where required.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Customer support — to respond to your enquiries, resolve disputes, and improve our support services.
• Platform improvement — to analyse usage patterns, conduct research, and develop new features and services.
• Marketing communications — to send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.
• Responsible gaming — to monitor gaming behaviour, enforce self-exclusion requests, and apply account limits in accordance with our Responsible Gaming Policy.

6 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 19jl processes your personal data on the following legal bases:

• Consent — where you have given clear, informed, and freely given consent to the processing of your data for a specific purpose, such as receiving marketing communications.
• Contractual necessity — where processing is necessary to perform our contract with you, including operating your account and processing transactions.
• Legal obligation — where processing is required to comply with a legal or regulatory obligation applicable to 19jl, including anti-money laundering reporting and age verification requirements.
• Legitimate interests — where processing is necessary for 19jl's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and freedoms.

Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing & Disclosure

19jl does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors — GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to facilitate deposits and withdrawals.
• Identity verification providers — third-party KYC (Know Your Customer) and AML (Anti-Money Laundering) service providers engaged to verify your identity and comply with regulatory requirements.
• Technology and infrastructure providers — cloud hosting, cybersecurity, and platform maintenance providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities — where required by applicable Philippine law, court order, or regulatory directive, including reporting obligations under anti-money laundering legislation.
• Professional advisers — lawyers, auditors, and consultants bound by professional confidentiality obligations, where necessary for legal or compliance purposes.
• Business transfers — in the event of a merger, acquisition, or sale of all or part of 19jl's business, your data may be transferred to the relevant successor entity, subject to equivalent privacy protections.

All third parties with whom 19jl shares personal data are contractually required to implement appropriate technical and organisational security measures and to process data only for the purposes specified by 19jl.

8 Data Retention

19jl retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data — retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering record-keeping requirements.
• Transaction records — retained for a minimum of five (5) years from the date of the transaction.
• Identity verification documents — retained for the period required by applicable KYC and AML regulations, typically five (5) years from the end of the business relationship.
• Support communications — retained for up to three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing consent records — retained for the duration of your consent and for a reasonable period thereafter to demonstrate compliance.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with 19jl's data disposal procedures.

9 Security Measures

19jl takes the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including financial and identity information.
• Strict role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Incident response procedures to detect, contain, and notify affected individuals and the National Privacy Commission (NPC) of any personal data breach within the timeframes required by law.

While 19jl takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

10 Cookies & Tracking Technologies

19jl uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the Platform, remember your preferences, and gather analytics data. The following types of cookies may be used:

• Strictly necessary cookies — essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies — used to remember your preferences, such as language settings and login status, to provide a more personalised experience.
• Analytics cookies — used to collect aggregated, anonymised data about how players use the Platform, helping us identify areas for improvement.
• Marketing cookies — used to deliver relevant promotional content and measure the effectiveness of our campaigns. These are only set with your consent.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

11 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 19jl:

• Right to be informed — the right to know how your personal data is being collected and processed, as set out in this Policy.
• Right of access — the right to request a copy of the personal data we hold about you and information about how it is processed.
• Right to rectification — the right to request correction of any inaccurate or incomplete personal data we hold 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 our legal retention 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 where technically feasible.
• Right to object — the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to restrict processing — the right to request that we limit the processing of your personal data in certain circumstances.
• Right to withdraw consent — where processing is based on your consent, the right to withdraw that consent at any time without affecting prior processing.
• Right to lodge a complaint — the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 14. We will respond to all valid requests within thirty (30) days, or within such other period as required by applicable law.

12 Minors

The 19jl Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations applicable to casino-style online gaming. 19jl does not knowingly collect personal data from individuals under the age of 21.

If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact us immediately using the details in Section 14.

Parents and guardians are encouraged to use parental control tools and to monitor their children's online activity to prevent access to age-restricted platforms. For more information on responsible gaming and player protection tools, please visit our Responsible Gaming page.

13 Changes to This Policy

19jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

Where changes are material, 19jl will endeavour to provide reasonable advance notice via the Platform or by email to your registered address. Your continued use of the Platform following the publication of any revised Policy constitutes your acceptance of the updated terms.

We encourage you to review this Policy periodically to stay informed about how 19jl protects your personal data.

14 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer (DPO):

Data Protection Officer — 19jl
Email: [email protected]

For general support enquiries, please contact: [email protected]

We aim to acknowledge all data subject requests within five (5) business days and to resolve them within thirty (30) days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.

For responsible gaming support, self-exclusion requests, or deposit limit adjustments, please visit our Responsible Gaming page. For general platform questions, visit our FAQ page.