Privacy Policy

1 Who We Are & Scope of This Policy

85jl ("we," "us," "our," or "the Company") operates the online gaming platform accessible at 85jl.one under PAGCOR authorization. For the purposes of Philippine data privacy law, 85jl is the personal information controller responsible for the collection and processing of personal data in connection with the Platform.

This Privacy Policy applies to all personal data collected from individuals who: (a) register or hold an account on the 85jl Platform; (b) visit the 85jl website without registering; (c) communicate with 85jl's customer support team; or (d) participate in any promotion or event organized by 85jl.

By registering an account or using the 85jl Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2 Information We Collect

2.1 Registration & Identity Data. When you create a 85jl account, we collect: full legal name; date of birth; Philippine mobile number; email address; and username.

2.2 Verification & KYC Data. To comply with PAGCOR's Know Your Customer requirements and the Anti-Money Laundering Act (AMLA), we may collect: government-issued photo ID (e.g., PhilSys National ID, passport, driver's license); selfie or liveness verification images; proof of address documents; and source of funds declarations where required by applicable law.

2.3 Financial Data. We collect transaction data related to your deposits, withdrawals, and gaming activity, including: GCash or Maya account references (partial, not full credentials); bank account details provided for withdrawals; transaction amounts, timestamps, and reference numbers; and bonus and wagering activity records.

2.4 Gaming Activity Data. We maintain records of your gameplay on the 85jl Platform, including games played, bets placed, outcomes, session duration, and win/loss history. This data is used for regulatory reporting, responsible gaming monitoring, and dispute resolution.

2.5 Technical & Device Data. We automatically collect certain technical data when you access the Platform: IP address; device type, operating system, and browser version; session timestamps and duration; pages visited and interactions within the Platform; and geolocation data (country/region level).

2.6 Communications Data. If you contact 85jl's customer support — whether via live chat, email, or any other channel — we retain records of those communications, including the content of messages and any attachments.

3 How We Collect Your Information

We collect personal information through the following means:

• Directly from you — when you register, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion;
• Automatically — through cookies, session logs, and device fingerprinting as you browse and use the Platform (see Section 7 on Cookies);
• From payment processors — GCash, Maya, and our banking partners provide transaction confirmation data to verify deposit and withdrawal activity;
• From identity verification providers — third-party KYC service providers may supply verification results, biometric match scores, and document authenticity assessments;
• From public and regulatory sources — where required for AMLA compliance, we may cross-reference data against government watchlists or PAGCOR exclusion registers.

4 How We Use Your Information

85jl uses the personal data it collects for the following purposes:

• Account creation and management — to register your account, authenticate your identity, and maintain your player profile;
• Service delivery — to provide access to games, process deposits and withdrawals in Philippine Peso, and administer bonuses and promotions;
• Regulatory compliance — to fulfil obligations under PAGCOR's licensing conditions, the AMLA as amended, and the Data Privacy Act of 2012, including KYC verification, suspicious transaction reporting, and record-keeping requirements;
• Age verification — to verify that all registered players are at least 21 years of age in compliance with PAGCOR regulations;
• Responsible gaming — to monitor gaming patterns, identify potentially problematic behaviour, and administer responsible gaming tools such as deposit limits, self-exclusion, and cooling-off periods;
• Fraud prevention and security — to detect and prevent unauthorized access, account takeover, money laundering, bonus abuse, and other fraudulent or prohibited activities;
• Customer support — to respond to your queries, complaints, and requests;
• Service improvement — to analyse usage patterns, improve the Platform's features, and optimize the player experience for Filipino users;
• Marketing communications — to send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where permitted under applicable law. You may opt out of marketing communications at any time.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, 85jl processes personal data on the following legal bases:

• Contractual necessity — processing required to perform the contract between you and 85jl (i.e., operating your gaming account, processing transactions);
• Legal obligation — processing required to comply with PAGCOR licensing conditions, AMLA obligations, and other applicable Philippine laws;
• Legitimate interests — processing necessary for fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights;
• Consent — for marketing communications and optional data processing activities where consent is the appropriate basis. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

6 Disclosure of Your Information

85jl does not sell your personal data to third parties. We may share your personal information with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors — GCash, Maya, GrabPay, BPI, BDO, Metrobank, and other payment partners, to process deposits and withdrawals;
• Game providers — PG Soft, JILI, Pragmatic Play, Evolution Gaming, and other licensed game developers, to the extent necessary for game functionality and fairness auditing;
• KYC and identity verification providers — third-party services used to verify player identity and document authenticity;
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies, where required by law, court order, or regulatory directive;
• IT and hosting service providers — data centres, cloud infrastructure providers, and technology vendors used to operate the Platform, bound by confidentiality obligations;
• Professional advisors — lawyers, auditors, and compliance consultants where necessary for legal or regulatory purposes.

7 Cookies & Tracking Technologies

The 85jl Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and gather analytics data. The types of cookies we use include:

• Strictly necessary cookies — required for the Platform to function, including authentication and session management. These cannot be disabled.
• Analytical cookies — used to understand how players interact with the Platform, which pages are visited most frequently, and where errors occur. This data is aggregated and anonymised.
• Functional cookies — used to remember your preferences, such as language settings and game lobby layout.
• Security cookies — used to detect and prevent fraudulent activity, multiple account abuse, and unauthorized access attempts.

By continuing to use the 85jl Platform, you consent to the use of cookies as described above. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair Platform functionality.

8 Data Retention

85jl retains personal data for as long as necessary to fulfil the purposes described in this Policy, including applicable regulatory and legal requirements. Specific retention periods include:

• Account and KYC data — retained for the duration of the account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements;
• Transaction records — retained for a minimum of five (5) years as required under applicable Philippine financial reporting and AMLA regulations;
• Customer support communications — retained for two (2) years or as long as a related dispute remains unresolved, whichever is longer;
• Marketing data — retained until you opt out of marketing communications, after which it is deleted or anonymised within thirty (30) days.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 85jl's data disposal procedures.

9 Data Security

85jl implements technical and organizational measures designed to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 85jl Platform;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Two-factor authentication (OTP via SMS) for account access;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Segregated storage of player funds from operational funds.

While 85jl takes all reasonable precautions, no internet-based system is entirely immune to security risks. You are responsible for maintaining the security of your account credentials. In the event of a personal data breach that poses a risk to your rights, 85jl will notify the National Privacy Commission and affected players in accordance with applicable law.

10 Your Rights Under the Data Privacy Act

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 85jl:

To exercise any of the above rights, contact 85jl's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will respond within fifteen (15) business days of receiving a valid request.

11 Children's Privacy

The 85jl Platform is strictly intended for adults aged 21 years and older. 85jl does not knowingly collect personal data from individuals under the age of 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 believe your child may have registered an account on 85jl, please contact us immediately at [email protected].

12 Cross-Border Data Transfers

Some of 85jl's service providers — including cloud infrastructure providers, game providers, and identity verification services — may be located outside the Philippines. Where personal data is transferred outside the Philippines, 85jl ensures that appropriate safeguards are in place as required by the Data Privacy Act and applicable NPC guidelines, including data processing agreements that require receiving parties to maintain standards equivalent to Philippine data privacy law. 85jl does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate contractual safeguards.

13 Amendments to This Policy

85jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Where changes are material, registered players will be notified by email or via a prominent notice on the Platform prior to the changes taking effect. The "Effective Date" at the top of this page reflects the date of the most recent update. Continued use of the Platform following any amendment constitutes your acceptance of the updated Policy.

14 How to Contact Us

For any questions, concerns, or requests related to this Privacy Policy or 85jl's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 via the chat widget on the 85jl Platform
• Subject Line: "Data Privacy Request" or "Privacy Policy Enquiry"

You also have the right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you are not satisfied with our response to a data privacy concern.