Privacy Policy

This Privacy Policy ("Policy") describes how 85jl ("the Platform", "we", "us", or "our") collects, processes, retains, and protects the personal data of individuals ("Members", "Users", or "you") who register for, access, or otherwise interact with the 85jl online casino and sportsbook platform accessible at https://85jl.vip.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and relevant issuances of the National Privacy Commission (NPC) of the Philippines. It also reflects obligations imposed on the 85jl platform by the Philippine Amusement and Gaming Corporation (PAGCOR) under the terms of 85jl's operating license.

By registering an account, making a deposit, or otherwise using the 85jl platform, you acknowledge that you have read and understood this Policy and that you consent to the processing of your personal data as described herein, where consent is the applicable legal basis for processing. For data processing activities carried out under other legal bases (such as legal obligation or legitimate interest), your consent is not required but you are nevertheless entitled to transparency regarding such processing, which this Policy provides.

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for personal data collected through the 85jl platform is the operator of the 85jl website, operating under a PAGCOR license for online gaming services in the Philippines.

85jl has appointed a Data Protection Officer (DPO) as required by the NPC's registration and compliance framework. The DPO is responsible for overseeing the platform's data protection practices, responding to rights requests, and serving as the point of contact for NPC inquiries regarding 85jl's data processing activities.

For all data privacy-related inquiries, rights requests, and complaints, you may contact the DPO directly via the contact information provided in Section 15 of this Policy.

85jl collects personal data across the following categories. For each category, the specific data points collected and the operational or legal necessity driving collection are identified.

85jl does not collect sensitive personal data as defined under Section 3(l) of the Data Privacy Act (such as health information, political or religious affiliation, or sexual orientation) except where a Member voluntarily discloses such information in a support communication. Where such data is received, it is not stored beyond the duration of the relevant support ticket.

The majority of personal data 85jl holds is provided directly by you at identifiable points in your interaction with the platform: account registration forms, KYC document uploads, payment method setup, support communications, and promotional opt-in selections. You are never obligated to provide more data than is necessary for the specific function you are using.

When you access the 85jl platform, certain technical data is collected automatically by the platform's systems as a necessary function of operating a secure online environment. This includes IP addresses, device identifiers, browser configuration, session timestamps, and page interaction logs. This data is used exclusively for security monitoring, fraud prevention, and platform performance optimisation — not for behavioural advertising.

When you complete a deposit or withdrawal via GCash, Maya, a Philippine bank, or any other supported payment method, the payment processor transmits to 85jl the minimum data required to confirm the transaction: typically the registered account name, transaction reference number, amount, and timestamp. 85jl does not receive, store, or have access to your full payment account credentials or PIN numbers.

For KYC verification, 85jl may engage third-party identity verification service providers to authenticate government-issued ID documents. These providers process your ID images under their own data handling agreements with 85jl and are contractually bound to process data only for the purpose of identity verification on 85jl's behalf.

The Philippine Data Privacy Act of 2012 requires that every personal data processing activity be grounded in a specific legal basis. 85jl processes your data on the following legal bases depending on the type of processing involved:

• Contractual Necessity: Processing necessary to fulfil the account agreement between you and 85jl — including account creation, deposit processing, game access, withdrawal execution, and customer support.
• Legal Obligation: Processing required to comply with Philippine law, PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) obligations, and NPC registration requirements. This includes KYC data collection, transaction record retention, and mandatory reporting to regulatory authorities.
• Legitimate Interest: Processing necessary for 85jl's legitimate business interests where those interests do not override your privacy rights — including fraud prevention, security monitoring, responsible gaming compliance monitoring, and platform optimisation analytics.
• Consent: Processing based on your freely given, specific, informed, and unambiguous agreement — including marketing communications (email, SMS, push notifications) and the use of non-essential cookies. You may withdraw consent at any time without affecting processing carried out on other legal bases.

85jl processes your personal data exclusively for the following defined purposes. We do not process personal data for any purpose incompatible with those stated here without first notifying you and, where required, obtaining your consent.

• Account administration: Creating, managing, and maintaining your 85jl account, including authentication, password recovery, session management, and account settings.
• Identity and age verification: Conducting KYC verification to satisfy PAGCOR's requirement that all registered Members are at least 21 years old and have provided accurate identity information.
• Payment processing: Facilitating deposits and withdrawals via GCash, Maya, Philippine banks, and other supported payment methods in PHP.
• Gaming services delivery: Providing access to games, recording game sessions, managing bonus eligibility, tracking VIP tier progress, and generating account statements.
• Fraud prevention and security: Detecting and investigating suspicious account activity, unauthorised access attempts, multi-accounting, bonus abuse, and financial fraud.
• Responsible gaming monitoring: Identifying patterns that may indicate problem gambling behaviour, enforcing Member-set limits, and administering self-exclusion requests.
• Regulatory compliance: Meeting PAGCOR reporting obligations, AMLA transaction reporting requirements, and NPC data protection obligations.
• Customer support: Responding to account inquiries, processing complaints, resolving disputes, and maintaining support communication records.
• Marketing communications (consent-based only): Sending promotional offers, game launch notifications, and VIP program updates to Members who have opted in to receive them.
• Platform improvement: Analysing aggregated, anonymised usage data to improve platform performance, game selection, user experience, and mobile optimisation for Philippine users.

85jl shares personal data with third parties only in the following defined circumstances. In all cases, data sharing is limited to the minimum data necessary for the stated purpose.

As a PAGCOR-licensed operator, 85jl is legally required to disclose Member identity and transaction data to PAGCOR upon formal request, and to the Anti-Money Laundering Council (AMLC) and other competent Philippine government authorities where required by law. These disclosures are mandatory and cannot be refused by 85jl.

Transaction data is shared with payment processors (GCash, Maya, BPI, BDO, and other integrated payment providers) solely to facilitate the execution of deposits and withdrawals. Payment processors are independent data controllers for their own systems and process data under their respective privacy policies and regulatory frameworks.

Game providers integrated with the 85jl platform (such as JILI, PG Soft, and Evolution) may receive a session token or pseudonymised player identifier to operate the game session. Full personal identity data is not shared with game providers as a matter of standard practice.

85jl engages third-party service providers acting as data processors for specific technical functions, including KYC verification services, cloud infrastructure providers, and customer support platform operators. All data processors are bound by written data processing agreements requiring them to process data only on 85jl's documented instructions and to maintain security standards equivalent to or exceeding 85jl's own.

The 85jl platform uses cookies and similar tracking technologies to operate the platform securely and to improve your user experience. Cookies are small text files placed on your device that allow the platform to recognise your session, maintain your login state, and recall your preferences.

• Strictly Necessary Cookies: Required for the platform to function. These include authentication session tokens, security cookies, and CSRF protection tokens. They cannot be disabled without rendering the platform inoperable. No consent is required for strictly necessary cookies under applicable law.
• Functional Cookies: Enable enhanced functionality such as remembering your game lobby preferences, language settings, and responsible gaming tool configurations. These are set with your implied consent by virtue of using the platform.
• Analytics Cookies: Collect anonymised, aggregated data about how Members use the platform — which game categories are visited most, which deposit flows have friction, and similar UX signals. No individually identifying data is included in analytics reports. You may opt out of analytics cookies via your account settings.
• Security and Fraud Prevention Cookies: Assist in detecting abnormal session behaviour, multi-account activity, and bot-driven interactions. These are necessary for the legitimate interest of platform security.

85jl does not use third-party advertising cookies, behavioural retargeting pixels, or tracking technologies that monitor your activity outside the 85jl platform. Your browsing behaviour on other websites is not tracked or collected by 85jl.

85jl retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law. The following retention schedule applies:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised such that it cannot be linked back to an identifiable individual. 85jl conducts periodic data retention audits to ensure compliance with this schedule.

85jl implements comprehensive technical and organisational security measures commensurate with the sensitivity of the data held and the risks associated with operating an online gaming platform handling real-money financial transactions in the Philippines.

• TLS 1.2+ encryption for all data in transit between Member devices and the 85jl platform.
• AES-256 encryption for sensitive data at rest in the platform's database systems.
• Multi-factor authentication (2FA via SMS OTP) available to all Members and mandatory for internal administrative accounts.
• Automated intrusion detection and anomaly monitoring on all platform access points.
• Regular third-party penetration testing and vulnerability assessment conducted by independent security firms.
• Segregated network architecture separating payment processing systems from general gaming infrastructure.

• Access to personal data is restricted on a strict need-to-know basis. Support agents, for example, access only the data necessary to resolve the specific issue they are handling.
• All staff with access to Member personal data complete mandatory data privacy training and are bound by contractual confidentiality obligations.
• An incident response procedure is in place for personal data breaches. In the event of a breach affecting Members, 85jl will notify the NPC within 72 hours of awareness and will notify affected Members without undue delay as required by NPC guidelines.

The Philippine Data Privacy Act of 2012 grants you the following rights with respect to your personal data held by 85jl. These rights are exercisable by submitting a written request to the 85jl Data Protection Officer using the contact details in Section 15.

Rights requests are processed within thirty (30) days of receipt as required by NPC guidelines. Where a request requires extended processing time due to complexity or volume, you will be notified within the initial 30-day period of the expected completion date.

The 85jl platform is strictly intended for use by adults aged 21 years and above, in accordance with Philippine gaming law and PAGCOR regulations. 85jl does not knowingly collect personal data from persons under the age of 21, and specifically prohibits registration by minors.

Where 85jl becomes aware that personal data has been submitted by or relates to a person under 21 years of age, all data relating to that individual will be deleted from the platform's systems without undue delay, subject only to any mandatory retention obligations under PAGCOR's underage gaming detection and reporting protocols.

The Philippines-based game providers, payment processors, and infrastructure used by the 85jl platform are operated from multiple jurisdictions. As a result, personal data processed by 85jl may be transferred to, stored in, or accessed from countries outside the Philippines.

Where personal data is transferred internationally, 85jl ensures that adequate safeguards are in place in accordance with NPC requirements for cross-border data transfers, including:

• Data processing agreements with recipient entities that impose data protection obligations equivalent to those required under Philippine law.
• Contractual clauses binding overseas processors to process Philippine Member data only in accordance with 85jl's documented instructions.
• Limiting international transfers to jurisdictions and entities that can demonstrate adequate data protection frameworks, assessed on a case-by-case basis.

You may request information about the specific cross-border transfers applicable to your account data by contacting the DPO. 85jl will provide details of the relevant safeguards within the standard rights response timeframe.

85jl reserves the right to amend this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC issuances, PAGCOR regulatory guidance, or 85jl's operational data processing practices.

For material changes — defined as modifications that expand the categories of data collected, introduce new purposes for processing, change the identity of data recipients, or materially affect Member rights — 85jl will provide at least fourteen (14) days' advance notice via the registered email address or mobile number on file, and will display a prominent notice on the platform for the duration of the notice period.

The effective date at the top of this Policy reflects the date of the most recent revision. It is your responsibility to review this Policy periodically. Continued use of the 85jl platform after the effective date of any revision constitutes acknowledgment of the updated Policy.

For all data privacy matters — including rights requests, consent withdrawal, data breach notifications, or privacy complaints — please contact the 85jl Data Protection Officer through the following channels:

• Email (Data Privacy matters): [email protected] with the subject line "Data Privacy Request — [Your Name]" for efficient routing to the DPO.
• Live Chat: Access 24/7 on the 85jl platform. For data privacy requests via live chat, state clearly that you are submitting a formal data rights request so that the interaction is escalated to the DPO team.
• Response commitment: The DPO team acknowledges all privacy requests within 72 hours and provides substantive responses within 30 days as mandated by NPC guidelines.

If you are not satisfied with 85jl's response to a privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC). Information on NPC complaint procedures is available through the NPC's official government website.