lj3 Privacy Policy – How We Handle Your Data

Sec. 1 Introduction

lj3 ("lj3," "we," "us," or "our") operates the online gaming platform accessible at https://lj3.club. This Privacy Policy ("Policy") describes how lj3 collects, uses, stores, shares, and protects the personal information of registered Members and visitors to lj3.club in the Philippines and other permitted jurisdictions.

lj3 is committed to processing personal data in a manner that is lawful, fair, transparent, and proportionate to the purposes for which it is collected. This Policy has been prepared in accordance with the requirements of Republic Act No. 10173 (the Philippine Data Privacy Act of 2012, "DPA") and its Implementing Rules and Regulations ("IRR"), as administered by the National Privacy Commission ("NPC").

Sec. 2 Data Controller Identity

For the purposes of the Philippine Data Privacy Act, lj3 acts as the Personal Information Controller ("PIC") for all personal data collected from Members and visitors through lj3.club. This means lj3 determines the purposes and means by which your personal data is processed.

lj3 has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with this Policy and applicable Philippine data protection law. Contact details for the lj3 DPO are provided in Section 15 of this Policy.

Where lj3 engages third-party service providers (such as payment processors, KYC verification services, and game content providers) to process data on its behalf, such providers act as Personal Information Processors ("PIPs") under written agreements that require them to process data only in accordance with lj3's instructions and this Policy.

Sec. 3 Categories of Personal Data We Collect

lj3 collects the following categories of personal data, depending on how you use lj3.club:

Sec. 4 How lj3 Collects Personal Data

4.1 Directly from You

lj3 collects most personal data directly from you when you: register an lj3 account; complete KYC identity verification; make a deposit or request a withdrawal; contact lj3 support via live chat or email; set responsible gaming preferences; or respond to lj3 promotions.

4.2 Automatically Through Your Use of lj3.club

lj3 automatically collects Technical Data when you access lj3.club through your device's browser. This includes your IP address, device identifiers, browser and operating system information, pages visited, session duration, and access timestamps. This collection occurs through server logs, session management systems, and analytics tools operated by lj3.

4.3 From Third-Party Service Providers

lj3 may receive identity verification results, fraud risk scores, and payment processing confirmations from third-party service providers engaged to support platform operations. These providers are contractually restricted to sharing only the minimum data necessary for the specified purpose.

4.4 Cookies and Similar Technologies

lj3.club uses cookies and similar local storage technologies as described in Section 10 of this Policy. You may manage cookie preferences through your browser settings, though disabling certain cookies may affect the functionality of lj3.club.

Sec. 5 Purposes of Processing

lj3 processes your personal data for the following purposes:

• Account creation and management — registering your lj3 account, authenticating your identity at login, and managing your account settings and preferences
• KYC and age verification — verifying that you are 21 years of age or older in compliance with PAGCOR guidelines, and confirming your identity for regulatory purposes
• Payment processing — processing deposits via GCash, Maya, BPI, BDO, and Metrobank, and processing withdrawal requests to your verified payment account
• Game operation and integrity — running games, recording bet placements and outcomes, resolving disputes, and maintaining the integrity of the lj3 gaming environment
• Anti-money laundering (AML) compliance — monitoring transactions for suspicious activity as required by the Anti-Money Laundering Act of 2001 (Republic Act No. 9160) and subsequent amendments, and reporting to the Anti-Money Laundering Council (AMLC) where obligated
• Responsible gaming — monitoring gaming patterns to identify potential problem gambling indicators and administering responsible gaming tools including deposit limits, session alerts, and self-exclusion
• Fraud prevention and platform security — detecting and preventing unauthorized access, account takeovers, bonus abuse, and other fraudulent or abusive activity
• Customer support — responding to enquiries, processing complaints, and resolving disputes raised by Members
• Legal compliance — fulfilling obligations under Philippine law, including data privacy, gaming regulation, and tax reporting requirements
• Service improvement — analysing anonymized and aggregated usage data to improve lj3's platform, game library, and Member experience

Sec. 6 Legal Bases for Processing

lj3 processes personal data on the following legal bases as defined under the Philippine Data Privacy Act and its IRR:

• Consent — where you have given lj3 your explicit consent to process specific categories of data for specific purposes, such as optional marketing communications
• Contractual necessity — where processing is necessary for lj3 to perform its obligations under the Member agreement, including account operation, payment processing, and game provision
• Compliance with a legal obligation — where processing is required to comply with applicable Philippine law, including AML reporting obligations and regulatory requirements
• Legitimate interests — where lj3 has a legitimate interest in processing data that is not overridden by your privacy rights, including fraud prevention, platform security, and business analytics
• Protection of vital interests — in exceptional circumstances where processing is necessary to protect the life or safety of a Member or third party

Sec. 7 Disclosure and Sharing of Personal Data

7.1 Authorised Third Parties

lj3 may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• Payment service providers — GCash, Maya, and partner banks (BPI, BDO, Metrobank) for the purpose of processing deposits and withdrawals. These providers receive only the minimum data necessary to execute the transaction.
• KYC and identity verification services — third-party providers that process Philippine government ID documents and biometric data solely for the purpose of verifying Member identity and age.
• Game content providers — JILI, PG Soft, Pragmatic Play, Spadegaming, and other game developers whose titles are hosted on lj3.club. Game providers may receive anonymized session and bet data for game operation purposes.
• IT infrastructure and hosting providers — cloud infrastructure and server hosting providers that process Technical Data as part of operating lj3.club's technology environment.
• Fraud prevention and cybersecurity services — specialist service providers used to detect and respond to security incidents, fraud attempts, and suspicious access patterns.

7.2 Regulatory and Legal Disclosures

lj3 will disclose Member personal data to competent regulatory and law enforcement authorities — including PAGCOR, the AMLC, the National Privacy Commission, and Philippine law enforcement agencies — where required to do so by applicable Philippine law, court order, or regulatory direction. lj3 will notify affected Members of such disclosures to the extent permitted by law.

7.3 No Sale of Personal Data

lj3 does not sell, rent, or trade Member personal data to any third party for commercial or marketing purposes. Personal data is shared with third parties only for the specific operational and compliance purposes described in this Section.

Sec. 8 Data Retention

lj3 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention obligations:

• Account and KYC records: Retained for a minimum of five (5) years from the date of account closure, as required by Philippine AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with the Anti-Money Laundering Act and BSP reporting requirements.
• Gaming history and bet records: Retained for a minimum of three (3) years from the date of each game session, for dispute resolution and regulatory audit purposes.
• Support communications: Retained for two (2) years from the date of each interaction, or longer where a formal dispute is open or legal proceedings are pending.
• Technical and access logs: Retained for a minimum of twelve (12) months for security monitoring and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with lj3's data destruction procedures. Anonymized, aggregated data may be retained indefinitely for statistical and analytical purposes without restriction.

Sec. 9 Security Measures

lj3 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and lj3.club
• Encrypted storage of sensitive data fields including passwords and identity document references
• Multi-factor authentication requirements for high-risk account actions including withdrawals and password changes
• Role-based access controls restricting lj3 staff access to Member data on a need-to-know basis
• Real-time fraud detection and anomaly monitoring systems
• Regular penetration testing and vulnerability assessments of lj3's platform infrastructure
• Incident response procedures aligned with NPC breach notification requirements

Sec. 10 Cookies & Similar Technologies

lj3.club uses the following categories of cookies and local storage technologies:

• Strictly necessary cookies: Essential for lj3.club to function, including session management, authentication state, and load balancing. These cookies cannot be disabled without preventing lj3.club from operating correctly.
• Functional cookies: Used to remember your preferences, such as language settings and game lobby view preferences. Disabling these cookies may reduce the personalisation of your lj3 experience.
• Analytics cookies: Used to collect anonymized and aggregated information about how Members navigate and use lj3.club, which lj3 uses to improve platform performance and user experience. These cookies do not identify you personally.
• Security cookies: Used to support lj3's fraud detection and platform security systems, including detection of suspicious login patterns and automated bot activity.

lj3.club does not use third-party advertising or behavioural tracking cookies. You may manage cookie settings through your browser's privacy controls. Note that blocking strictly necessary cookies will prevent lj3.club from functioning correctly and may prevent lj3 Login from working.

Sec. 11 Children's and Minors' Privacy

lj3.club is strictly prohibited to persons under twenty-one (21) years of age. lj3 does not knowingly collect personal data from individuals under 21 years of age. This restriction is consistent with PAGCOR's minimum age requirement for casino-style gaming in the Philippines.

lj3 enforces the 21+ age requirement through mandatory KYC identity verification, which requires submission of a valid Philippine government-issued identification document confirming the Member's date of birth. Any account found to have been created by a person under 21 years of age will be immediately closed and all associated personal data will be deleted, subject only to mandatory retention obligations under applicable law.

If lj3 becomes aware that personal data has been collected from a person under 21 years of age without appropriate verification, lj3 will take immediate steps to delete that data and close the associated account.

Sec. 12 Exercising Your Privacy Rights

lj3 Members may exercise their rights under the Philippine Data Privacy Act by submitting a written request to the lj3 Data Protection Officer at [email protected]. To protect your privacy and prevent unauthorized access to your data, all privacy rights requests must be submitted from your registered contact details and may require identity verification before processing.

lj3 will acknowledge receipt of a privacy rights request within five (5) business days and will provide a substantive response within thirty (30) calendar days. Where the complexity or volume of requests requires additional time, lj3 will notify you of the extension and provide an estimated completion date.

The following rights are available to lj3 Members under the DPA:

• Right to be informed — the right to know what data is being collected, the purposes of processing, and who data is shared with (addressed by this Policy)
• Right of access — the right to receive a copy of your personal data held by lj3
• Right to rectification — the right to have inaccurate or incomplete data corrected
• Right to erasure or blocking — the right to request deletion of data that is no longer necessary, subject to legal retention obligations
• Right to data portability — the right to receive a machine-readable copy of your data
• Right to object — the right to object to processing for direct marketing or on grounds of legitimate interest
• Right to damages — the right to seek compensation for harm resulting from a violation of the DPA
• Right to complain — the right to file a complaint with the National Privacy Commission of the Philippines

Sec. 13 Cross-Border Data Transfers

lj3's primary operations and data processing activities are based in the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, including game content providers and cloud infrastructure providers whose systems may be hosted in other jurisdictions.

Where personal data is transferred outside the Philippines, lj3 ensures that appropriate safeguards are in place, including contractual clauses requiring receiving parties to maintain data protection standards equivalent to those required by the Philippine Data Privacy Act. lj3 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate contractual protections.

Sec. 14 Amendments to This Policy

lj3 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the services offered on lj3.club. Where changes are material, lj3 will notify Members via in-platform notification or registered contact details with not less than seven (7) calendar days' notice prior to the effective date of the amended Policy.

The effective date of the current version of this Policy is displayed at the top of this page. Members are encouraged to review this Policy periodically. Continued use of lj3.club after the effective date of any amendment constitutes acceptance of the updated Policy.

The current version of this Privacy Policy is always available at lj3.club/privacy-policy. Previous versions may be requested from the lj3 Data Protection Officer.

Sec. 15 Contact & Data Protection Officer

For all privacy-related enquiries, rights requests, or complaints regarding lj3's handling of your personal data, please contact the lj3 Data Protection Officer:

• Email: [email protected] (subject line: "Data Privacy Enquiry" or "Privacy Rights Request")
• Live Chat: Available 24/7 through lj3.club — ask to speak with the Data Protection Officer for formal privacy matters
• Response time: Acknowledgement within five (5) business days; substantive response within thirty (30) calendar days

If you are not satisfied with lj3's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines. Information about filing a complaint with the NPC is available on the NPC's official website.