Privacy Policy

01 Introduction

18JL Win ("18jl win", "we", "us", "our") is committed to protecting the privacy and personal data of every player who uses the 18jl win platform. This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information when you access or use the 18jl win website, mobile application, and related services (collectively, the "Platform").

This Policy applies to all registered and unregistered users of the 18jl win Platform, including players based in Manila, Cebu, Davao, Quezon City, Makati, and across the Philippines. It should be read together with our Terms & Conditions and Responsible Gaming Policy.

By accessing or using the 18jl win Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform.

02 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and applicable data protection legislation, 18JL Win is the personal information controller responsible for your personal data collected through the Platform.

As the personal information controller, 18jl win determines the purposes and means of processing your personal data and is accountable for ensuring that such processing is carried out in accordance with applicable law and this Privacy Policy.

If you have any questions about how 18jl win handles your personal data, or if you wish to exercise any of your data subject rights, please contact our Data Privacy Officer using the contact details provided in Section 15 of this Policy.

03 Data We Collect

18jl win collects the following categories of personal data from users of the Platform:

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data unless specifically required by law or regulatory obligation and with your explicit consent.

04 How We Collect Data

18jl win collects your personal data through the following means:

• Direct Interactions: Information you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting our support team, or responding to surveys and promotions on the 18jl win Platform.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 8 for more details on cookies.
• Third-Party Sources: Identity and financial verification data received from our KYC/AML service providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), and fraud prevention partners.
• Regulatory Sources: Information received from PAGCOR or other regulatory authorities in connection with our licensing obligations or compliance requirements.
• Publicly Available Sources: In limited circumstances, 18jl win may supplement your profile with information from publicly available sources to assist with identity verification or fraud prevention.

05 How We Use Your Data

18jl win uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 18jl win player account, including processing your registration, verifying your identity, and managing your account settings.
• Transaction Processing: To process deposits, withdrawals, and wagers, and to maintain accurate records of all financial transactions conducted through your account.
• Legal and Regulatory Compliance: To comply with our obligations under Philippine law, including the Anti-Money Laundering Act, the Data Privacy Act of 2012, and PAGCOR regulatory requirements. This includes conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks.
• Responsible Gaming: To monitor your gaming activity and identify patterns that may indicate problem gambling, and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, unauthorised account access, and other illegal or prohibited activities on the Platform.
• Platform Improvement: To analyse usage patterns and player behaviour in aggregate to improve the performance, features, and user experience of the 18jl win Platform.
• Marketing Communications: To send you promotional offers, bonuses, and updates about 18jl win, where you have consented to receive such communications. You may opt out at any time.

06 Legal Basis for Processing

18jl win processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your 18jl win account, process your transactions, and provide the gaming services you have registered to use.
• Legal Obligation: Processing is required to comply with our legal and regulatory obligations, including KYC/AML requirements, PAGCOR licensing conditions, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform, including fraud prevention, security monitoring, and platform analytics, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

07 Data Sharing & Disclosure

18jl win does not sell your personal data. We may share your personal information with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals. These providers process your data under their own privacy policies and security standards.
• Identity Verification Providers: Third-party KYC and AML service providers engaged by 18jl win to verify your identity and screen against sanctions and watchlists as required by Philippine law.
• Technology and Hosting Partners: Cloud hosting providers, software vendors, and IT service providers who support the operation of the 18jl win Platform. These parties process data only on our instructions and are bound by confidentiality obligations.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other government bodies where disclosure is required by law, court order, or regulatory direction.
• Professional Advisers: Lawyers, auditors, and accountants engaged by 18jl win in connection with legal proceedings, compliance reviews, or business operations, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of 18jl win's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom 18jl win shares personal data are required to handle that data in accordance with applicable law and to implement appropriate security measures.

08 Cookies & Tracking Technologies

The 18jl win Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and gather analytics data. The following types of cookies may be used:

• Essential Cookies: Strictly necessary for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations to personalise your 18jl win experience.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform — such as which games are most popular and how long sessions last — to help us improve the Platform.
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorised access attempts on the 18jl win Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 18jl win Platform. For essential cookies, no opt-out is available as they are required for the Platform to operate.

09 Data Retention

18jl win retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with 18jl win, and for a minimum of five (5) years following account closure, in accordance with Philippine AML and gaming regulatory requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC/Verification Documents: Identity verification documents are retained for a minimum of five (5) years following the end of the business relationship, or longer if required by applicable law.
• Support Communications: Customer support records are retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing Data: Retained until you withdraw consent or opt out of marketing communications, after which your data will be suppressed from marketing lists.

When personal data is no longer required, 18jl win will securely delete or anonymise it in accordance with our data disposal procedures.

10 Data Security

18jl win implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 18jl win Platform.
• Encryption of sensitive data at rest, including financial information and identity documents stored on our servers.
• Role-based access controls ensuring that only authorised 18jl win personnel can access personal data, and only to the extent required for their specific job functions.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform infrastructure.
• Multi-factor authentication options for player accounts to reduce the risk of unauthorised access.
• Incident response procedures to detect, contain, and notify affected parties in the event of a personal data breach, in accordance with the requirements of the National Privacy Commission.

While 18jl win takes all reasonable steps to protect your personal data, no system is completely immune to security risks. You are responsible for maintaining the confidentiality of your own account credentials and for notifying us immediately if you suspect any unauthorised access to your 18jl win account.

11 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 18jl win:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data that 18jl win holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by 18jl win.
• 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 Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that 18jl win has not handled your personal data in accordance with applicable law.

To exercise any of these rights, please contact our Data Privacy Officer using the details in Section 15. We will respond to all valid requests within thirty (30) days, or within such other period as required by applicable law. We may need to verify your identity before processing your request.

12 Children's Privacy

The 18jl win Platform is strictly intended for adults aged 21 years and above. 18jl win 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, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the 18jl win Platform or provided us with personal data, please contact our support team immediately so that we can take appropriate action.

18jl win employs age verification procedures during the registration process to prevent underage access to the Platform. These procedures are a core part of our commitment to responsible gaming and compliance with Philippine gaming regulations.

13 International Data Transfers

The 18jl win Platform is operated primarily within the Philippines. However, some of our technology partners and service providers may be located in other countries, which means your personal data may be transferred to and processed in jurisdictions outside the Philippines.

Where such transfers occur, 18jl win ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised under Philippine law.
• Implementing contractual clauses with overseas recipients that require them to protect your personal data to standards equivalent to those required under the Philippine Data Privacy Act of 2012.
• Conducting due diligence on all overseas data processors to verify their security practices and compliance posture before engaging their services.

By using the 18jl win Platform, you acknowledge and consent to the transfer of your personal data to overseas service providers where necessary for the operation of the Platform, subject to the safeguards described above.

14 Changes to This Policy

18jl win reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, we will notify registered players by email and/or by displaying a prominent notice on the 18jl win Platform prior to the changes taking effect.

The effective date at the top of this Policy will be updated each time a new version is published. We encourage you to review this Privacy Policy periodically to stay informed about how 18jl win is protecting your personal data.

Your continued use of the 18jl win Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should discontinue use of the Platform and may request account closure.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 18jl win handles your personal data, please contact our Data Privacy Officer. We are committed to addressing all privacy-related enquiries promptly and transparently.