ljlj3 Privacy
Policy

1. Introduction & Scope

This Privacy Policy ("Policy") describes how ljlj3 ("ljlj3", "we", "us", or "our"), operating the online gaming platform accessible at ljlj3.cam, collects, uses, stores, processes, and discloses personal information in connection with the services we provide to registered players and website visitors in the Philippines.

This Policy applies to all personal data collected through: (a) the ljlj3 website and mobile-optimized platform at ljlj3.cam; (b) the account registration and KYC verification process; (c) all gaming sessions, deposits, withdrawals, and bonus transactions conducted through the ljlj3 platform; (d) all communications with the ljlj3 customer support team; and (e) any marketing communications you have consented to receive from ljlj3.

This Policy is governed by Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), as administered by the National Privacy Commission (NPC) of the Philippines. ljlj3 also complies with all applicable PAGCOR data governance requirements and Republic Act No. 9160, the Anti-Money Laundering Act (AMLA), as amended.

By creating an ljlj3 Account or by continuing to use the ljlj3 platform after being presented with this Policy, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and its IRR, ljlj3 is the Personal Information Controller (PIC) responsible for your personal data collected through the ljlj3 platform.

ljlj3 has designated a Data Protection Officer (DPO) in accordance with Section 21 of the DPA IRR. The DPO is responsible for overseeing ljlj3's data protection strategy, ensuring compliance with the DPA, and serving as the primary point of contact for data subjects exercising their rights under the DPA. Contact details for the ljlj3 DPO are provided in Section 15 of this Policy.

ljlj3 is registered with the National Privacy Commission (NPC) as required under NPC Circular No. 17-01. Our NPC registration reflects the data processing activities described in this Policy.

3. Personal Data We Collect

ljlj3 collects the following categories of personal data from players and website visitors:

4. How We Collect Your Data

ljlj3 collects personal data through the following mechanisms:

• Direct Collection: Information you actively provide during account registration (name, mobile number, email, date of birth), KYC document submission, payment transactions, form submissions, and customer support communications.
• Automated Collection: Technical data collected automatically when you access the ljlj3 platform — including IP address, device identifiers, browser fingerprint, session timestamps, and usage behaviour — through server logs, cookies, and similar tracking technologies. See Section 11 for full cookie details.
• Third-Party Sources: Identity verification data confirmed by licensed KYC verification service providers. Payment status confirmations from GCash, Maya, and Philippine bank payment processors. Fraud risk signals from anti-fraud service providers integrated into the ljlj3 payment and account systems.
• Regulatory Sources: Watchlist screening results from AMLC-approved screening tools used to comply with AMLA obligations, including UNSC sanctions list and AMLC-designated persons databases.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, ljlj3 relies on the following lawful bases for processing your personal data:

1. Contractual Necessity (Section 12[b], DPA): Processing required to perform the contract between ljlj3 and the Player — including account creation, gameplay, deposits, withdrawals, and bonus management.
2. Legal Obligation (Section 12[c], DPA): Processing required to comply with ljlj3's legal obligations under PAGCOR regulations, AMLA (RA 9160), the DPA itself, and applicable court orders — including KYC verification, suspicious transaction reporting, and data retention mandated by law.
3. Legitimate Interests (Section 12[f], DPA): Processing necessary for ljlj3's legitimate interests, where those interests are not overridden by your rights — including fraud detection, platform security, responsible gaming monitoring, and product improvement through aggregated analytics.
4. Consent (Section 12[a], DPA): Processing based on your freely given, specific, informed, and unambiguous consent — including sending you marketing communications about ljlj3 promotions, bonuses, and new game releases. You may withdraw marketing consent at any time through your Account settings.

6. How We Use Your Personal Data

ljlj3 uses the personal data we collect for the following specific purposes:

• Account Management: Creating, verifying, maintaining, and securing your ljlj3 Account, including authentication, password recovery, session management, and two-factor authentication (2FA).
• Identity Verification (KYC): Confirming your identity, age (21+), and eligibility to use the ljlj3 platform in accordance with PAGCOR regulations and Philippine law.
• Payment Processing: Processing your deposits, withdrawals, and wallet transactions through GCash, Maya, BPI, BDO, Metrobank, USDT, Coins.ph, and 7-Eleven payment channels.
• Gaming Services: Operating casino games, sports betting markets, bingo rooms, and other ljlj3 services; recording game session logs for dispute resolution and regulatory audit purposes.
• Regulatory Compliance: Meeting PAGCOR reporting obligations, AMLA suspicious transaction reporting requirements, NPC data governance requirements, and any lawful regulatory request or court order.
• Fraud and Security: Detecting, investigating, and preventing fraud, money laundering, multi-account abuse, bonus abuse, unauthorized access, and other prohibited activities on the ljlj3 platform.
• Responsible Gaming: Monitoring gaming behaviour to support responsible gaming obligations — including identifying patterns associated with problem gambling and proactively offering support tools where appropriate, as required under PAGCOR responsible gaming guidelines.
• Customer Support: Responding to your enquiries, resolving disputes, processing complaints, and delivering the 24/7 Filipino-language support service operated by ljlj3.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the ljlj3 platform — including game loading performance, payment flow optimisation, and mobile experience on Philippine networks.
• Marketing Communications (Consent-Based): Sending you promotional offers, bonus notifications, new game announcements, and event invitations where you have provided explicit marketing consent. You may opt out at any time.

7. Data Sharing & Disclosure

ljlj3 does not sell, rent, or trade your personal data to third parties. We share your personal data only in the following circumstances and with the following categories of recipient:

• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and any other Philippine government authority where disclosure is required by law, regulation, or valid legal process. ljlj3 will comply with all lawful data requests from Philippine authorities and will notify affected players where legally permitted to do so.
• KYC and Identity Verification Providers: Licensed third-party identity verification service providers used to confirm the authenticity of government-issued Philippine ID documents submitted during the KYC process. These providers are contractually bound to process data solely for verification purposes and to maintain confidentiality standards compliant with the DPA.
• Payment Processors: Certified Philippine payment service providers — including GCash (Globe Fintech Innovations), Maya (Voyager Innovations), and Philippine banking partners — to facilitate deposit and withdrawal transactions. Payment processors receive only the data necessary to process each transaction.
• Game Content Providers: Licensed gaming software providers (such as JILI, PG Soft, Pragmatic Play, and Spadegaming) may receive technical session identifiers necessary to operate game rounds within their platforms. These providers do not receive your identity documents, financial data, or contact information.
• IT and Security Service Providers: Cloud infrastructure, cybersecurity, anti-fraud, and platform operations service providers who process data on behalf of ljlj3 as Personal Information Processors (PIPs) under binding Data Processing Agreements (DPAs) that enforce DPA-compliant data protection standards.
• Professional Advisers: Legal counsel, auditors, and compliance consultants where disclosure is necessary for the exercise of legal rights or professional duties, subject to professional confidentiality obligations.

8. Data Retention

ljlj3 retains your personal data for as long as is necessary for the purposes described in this Policy and to meet our legal obligations under Philippine law. The following retention periods apply:

• Account and Identity Data (Active Accounts): Retained for the duration of your active ljlj3 Account relationship, plus five (5) years following Account closure — as required by AMLA record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship or the date of the relevant transaction, as required under AMLA (RA 9160) and applicable PAGCOR record-keeping guidelines.
• Transaction Records (Financial Data): Retained for a minimum of five (5) years from the date of each transaction, in accordance with AMLA obligations and generally accepted accounting standards applicable under Philippine law.
• Gaming Session Logs: Retained for three (3) years following the conclusion of each game session, for dispute resolution and PAGCOR audit purposes.
• Customer Support Records: Retained for two (2) years following the resolution of each support interaction, for quality assurance and dispute reference purposes.
• Marketing Consent Records: Retained for the duration of your consent plus one (1) year following withdrawal of consent, to demonstrate compliance with consent requirements under the DPA.
• Technical/Log Data: Retained for ninety (90) days, unless retention is extended due to an active security investigation or legal proceeding.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with ljlj3's data disposal procedures. Anonymised data retained beyond these periods cannot be used to identify individual players.

9. Data Security

ljlj3 implements a layered set of technical, administrative, and physical security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption in Transit: All communications between your device and the ljlj3 platform are encrypted using TLS 1.2 or higher (256-bit SSL). HTTPS is enforced across the entire ljlj3 domain with HSTS headers.
• Encryption at Rest: Personal data stored in ljlj3 databases — including KYC documents and financial identifiers — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data by ljlj3 staff is restricted on a strict need-to-know basis, enforced through role-based access control (RBAC). All staff access to player data is logged and auditable.
• Password Security: Player passwords are stored only as salted cryptographic hashes — ljlj3 staff cannot view your password in plain text. Multi-factor authentication (MFA) is enforced for all ljlj3 internal administrative system access.
• Network Security: ljlj3 platform infrastructure is protected by web application firewalls (WAF), intrusion detection and prevention systems (IDS/IPS), and DDoS mitigation services.
• Vulnerability Management: Regular penetration testing, vulnerability scanning, and code security reviews are conducted by independent security professionals to identify and remediate security risks.
• Incident Response: ljlj3 maintains a documented data breach response plan. In the event of a personal data breach that poses a real risk of serious harm to data subjects, ljlj3 will notify the NPC within 72 hours of discovery and will notify affected players as required under NPC Circular No. 16-03.

While ljlj3 implements rigorous security measures, no internet-based system can guarantee absolute security. Players are encouraged to use strong, unique passwords, enable two-factor authentication on their ljlj3 Account, and exercise caution when accessing their Account on shared or public devices.

10. Your Data Rights Under Philippine Law

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ljlj3. To exercise any of these rights, please contact the ljlj3 Data Protection Officer using the details in Section 15. ljlj3 will respond to all verified rights requests within thirty (30) calendar days of receipt.

11. Cookies & Tracking Technologies

ljlj3 uses cookies and similar tracking technologies to operate the platform, remember your preferences, maintain session security, and understand how the platform is used. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential to the operation of the ljlj3 platform — these include session authentication cookies that keep you logged in during a gaming session, CSRF protection tokens, and load balancing cookies. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences — such as language setting, last game played, and responsible gaming display settings — to provide a personalised experience. These are not shared with third parties.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players navigate and use the ljlj3 platform — which game categories are most visited, typical session flow, and technical error rates. This data is used solely for internal product improvement and is not shared with external analytics platforms.
• Security Cookies: Used to detect and prevent fraudulent login attempts, bot activity, and multi-account creation by analysing device fingerprint consistency and IP behaviour patterns.

You can manage or delete cookies through your browser settings. Disabling strictly necessary cookies will prevent the ljlj3 platform from functioning correctly. You can block functional and analytics cookies without affecting core platform operation, though your experience may be less personalised.

12. Children's Privacy

The ljlj3 platform is strictly restricted to individuals who are at least 21 years of age, as required by PAGCOR regulations governing casino-style gambling in the Philippines. ljlj3 does not knowingly collect personal data from anyone under the age of 21.

Age verification is conducted during the account registration and KYC processes. If ljlj3 discovers or is notified that personal data has been collected from an individual who is under 21 years of age, we will immediately close the associated Account, return any real-money balance to the relevant payment source, delete the personal data of the underage individual to the extent permitted by our legal retention obligations, and report the matter to PAGCOR as required.

If you are a parent or guardian and believe a person under 21 has registered on the ljlj3 platform, please contact the ljlj3 Data Protection Officer immediately using the details in Section 15.

13. Cross-Border Data Transfers

Some of ljlj3's service providers — including cloud infrastructure providers and gaming software providers — may process personal data on servers located outside the Philippines. Where personal data is transferred internationally, ljlj3 ensures that such transfers comply with Section 21 of the DPA and NPC Advisory Opinion No. 2017-046.

Specifically, ljlj3 requires that all international data transfers be protected by one of the following safeguards: (a) a binding Data Processing Agreement (DPA) that incorporates standard contractual clauses approved by the NPC; (b) the recipient being located in a country or territory deemed to provide an adequate level of data protection by the NPC; or (c) other lawful transfer mechanisms recognised under the DPA IRR.

Your personal data is never transferred internationally for advertising, marketing profiling, or data brokerage purposes.

14. Updates to This Policy

ljlj3 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. When material changes are made to this Policy, ljlj3 will: (a) post the updated Policy on this page with a revised "Last Updated" date; (b) notify registered players via their registered email address or via in-platform notification at least fourteen (14) days before the changes take effect; and (c) where required by law or regulation, seek fresh consent where a change affects the legal basis on which we process your data.

Continued use of the ljlj3 platform after the effective date of an updated Privacy Policy constitutes acceptance of the updated terms. If you do not agree with material changes to this Policy, you may close your ljlj3 Account in accordance with the account closure process described in our Terms and Conditions.

15. Contact & Complaints

For all privacy-related enquiries, data subject rights requests, data breach notifications, or concerns about ljlj3's data processing practices, please contact the ljlj3 Data Protection Officer through the following channels:

• Live Chat: Available 24/7 from your logged-in ljlj3 Account dashboard — select "Privacy & Data" from the support topic menu
• Email: [email protected] — please include "Privacy Request" in the subject line

ljlj3 will acknowledge all DPO communications within five (5) business days and respond substantively within thirty (30) calendar days. If you are not satisfied with ljlj3's response to your privacy concern or rights request, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through the NPC's official complaints procedure.