ajjl Privacy Policy

This Privacy Policy is issued by ajjl ("ajjl", "we", "us", "our"), the operator of the online gaming platform accessible at ajjl.app ("Platform"). ajjl acts as the personal information controller in respect of all personal data collected through the Platform and is responsible for ensuring that such data is processed in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the applicable issuances of the National Privacy Commission ("NPC").

ajjl also operates under the PAGCOR regulatory framework, which imposes additional data handling and reporting obligations, particularly in relation to player identity verification, transaction monitoring, and anti-money laundering compliance.

ajjl collects personal data from you through multiple channels, including your account registration, your use of Platform features, your financial transactions, and your interactions with our customer support team. The categories of personal data we collect are described in the table below:

ajjl uses your personal data only for the purposes described below. We will not process your data in a manner that is incompatible with these stated purposes:

• Account Management: To create, maintain, verify, and administer your ajjl account, including processing your registration, managing your login credentials, and updating your account details.
• Identity Verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR requirements and Philippine law. This includes cross-referencing your submitted documents against authoritative identity databases where applicable.
• Payment Processing: To process your deposits and withdrawals via GCash, Maya, GrabPay, QR Ph, InstaPay, PesoNet, BPI, BDO, Metrobank, 7-Eleven CLiQQ, and USDT, and to maintain accurate records of all financial transactions on your account.
• Gaming Services: To enable you to participate in all games and betting activities available on the Platform, including bingo, slots, live dealer games, sabong, and sports betting.
• Responsible Gaming: To monitor gaming activity for indicators of problem gambling behaviour, apply responsible gaming limits you have set on your account, and communicate with you regarding responsible gaming tools and self-exclusion options.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct as required by Republic Act No. 9160 (Anti-Money Laundering Act) and PAGCOR regulations.
• Regulatory Compliance: To fulfil reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine regulatory authorities as required by applicable law.
• Customer Support: To respond to your enquiries, complaints, and support requests submitted via live chat or email.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided your express consent. You may withdraw this consent at any time via your account settings.
• Platform Improvement: To analyse aggregated and anonymised usage data for the purpose of improving Platform performance, game offerings, and the overall user experience.

Under the Data Privacy Act of 2012, ajjl is required to have a lawful basis for each processing activity involving your personal data. The legal bases on which ajjl relies are as follows:

• Contractual Necessity: The processing of identity data, contact data, financial data, and gaming data is necessary for the performance of the contract between you and ajjl (i.e., the Terms and Conditions you agreed to upon registration). Without this processing, ajjl cannot provide the Platform services to you.
• Legal Obligation: The processing of identity data for KYC purposes, financial transaction data for AML reporting, and certain gaming data for PAGCOR regulatory submissions is required by applicable Philippine laws and regulations. ajjl has no discretion to waive these processing activities.
• Legitimate Interests: The processing of technical data for security monitoring, fraud detection, and Platform improvement is carried out on the basis of ajjl's legitimate interests, balanced against your rights and freedoms as a data subject. ajjl has conducted legitimate interests assessments for these processing activities.
• Consent: The processing of your personal data for marketing communications is based solely on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

The ajjl Platform uses cookies and similar tracking technologies to provide, secure, and improve the service. A cookie is a small text file placed on your device when you visit the Platform. The categories of cookies we use are described below:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as account login, session management, and security controls. These cookies cannot be disabled without impairing Platform functionality.
• Functional Cookies: These cookies remember your preferences, such as language settings and responsible gaming limit configurations, to provide a more personalised experience on return visits.
• Analytics Cookies: These cookies collect anonymised and aggregated information about how players use the Platform — such as which games are most popular and how long sessions typically last — to help ajjl improve the Platform experience. No individually identifiable information is processed through analytics cookies.
• Security Cookies: These cookies help ajjl detect and prevent fraudulent activity, including account takeover attempts, bot activity, and suspicious login patterns.

You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent you from using certain features of the Platform. ajjl does not use third-party advertising cookies or cross-site tracking technologies.

ajjl does not sell, rent, or trade your personal data to third parties for their own independent commercial purposes. Your personal data may be shared with third parties only in the following limited circumstances:

• Payment Processors: ajjl shares the minimum necessary financial data with payment service providers (such as GCash, Maya, GrabPay, BPI, BDO, and Metrobank) solely to process your deposit and withdrawal transactions.
• Identity Verification Providers: ajjl may engage licensed third-party KYC service providers to assist in verifying identity documents submitted during account registration. These providers process your data solely on ajjl's instructions and are contractually bound to protect it.
• Regulatory Authorities: ajjl is legally required to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities upon lawful request or as mandated by applicable law.
• IT Service Providers: ajjl uses third-party cloud hosting and technology service providers to operate the Platform infrastructure. These providers access personal data only to the extent necessary to provide their services and are bound by strict data processing agreements.
• Professional Advisers: ajjl may share personal data with legal counsel, auditors, and compliance consultants where strictly necessary for the provision of professional services, subject to appropriate confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of ajjl's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer.

The ajjl Platform is operated primarily within the Philippines and processes most personal data within Philippine territory. However, some of ajjl's third-party IT service providers and cloud infrastructure partners may be located outside the Philippines.

Where personal data is transferred to a country outside the Philippines, ajjl ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the Data Privacy Act of 2012, including:

• Entering into Standard Contractual Clauses or equivalent contractual data transfer mechanisms with the recipient entity.
• Transferring data only to countries that the NPC has determined offer an adequate level of data protection.
• Implementing additional technical safeguards such as end-to-end encryption where cross-border transfers occur.

You may request information about the specific safeguards applied to any international transfer of your personal data by contacting ajjl's Data Protection Officer at the details provided in Section 13.

ajjl retains your personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law and PAGCOR regulations. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, ajjl will securely delete or irreversibly anonymise your personal data. Where deletion is not immediately possible due to technical constraints, the data will be isolated and protected from further processing until deletion is completed.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in respect of the personal data ajjl holds about you. ajjl will respond to all verified data subject requests within fifteen (15) calendar days of receipt:

The ajjl Platform is strictly intended for adults who are 21 years of age or older, in accordance with Philippine gambling laws and PAGCOR regulations. ajjl does not knowingly collect personal data from individuals under the age of 21.

If ajjl becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to:

• Suspend and permanently close the relevant account.
• Refund any deposits made, less any amounts lost through gambling activity, where the refund is legally permissible.
• Permanently delete all personal data associated with the underage account, subject to any overriding legal obligations.
• Report the incident to PAGCOR as required under the applicable regulatory framework.

If you are a parent or guardian and believe that a minor under 21 has registered on the ajjl Platform, please contact us immediately at [email protected] so that we can take prompt action.

ajjl implements a comprehensive set of technical, organisational, and procedural security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the ajjl Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Personal data stored at rest is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within ajjl's systems is restricted to authorised personnel on a strict need-to-know basis. All internal access is logged and subject to regular audit review.
• Multi-Factor Authentication: Sensitive administrative access to systems containing personal data requires multi-factor authentication in addition to password-based login.
• Penetration Testing: ajjl conducts regular third-party penetration tests and vulnerability assessments to identify and remediate security weaknesses in the Platform infrastructure.
• Incident Response: ajjl maintains a documented data breach incident response plan. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ajjl will notify the NPC within 72 hours of becoming aware of the breach and will notify affected players without undue delay.
• Staff Training: All ajjl personnel who handle personal data undergo mandatory data privacy training upon onboarding and at regular intervals thereafter.

ajjl reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, our data processing practices, or the features and services available on the Platform.

When material changes are made to this Policy, ajjl will:

• Update the "Last Updated" date at the top of this Policy.
• Notify registered players via email or in-Platform notification at least seven (7) days before the revised Policy takes effect.
• Where required by the Data Privacy Act of 2012 or NPC guidance, obtain your fresh consent before processing your data under materially different terms.

Your continued use of the ajjl Platform following the effective date of any amended Privacy Policy constitutes your acknowledgement of the changes. We encourage you to review this Policy periodically to stay informed about how ajjl protects your personal information.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way ajjl processes your personal data, please contact our Data Protection Officer using the details below:

• Email: [email protected] — please use the subject line "Privacy Enquiry" or "Data Subject Rights Request" for the fastest response.
• Live Chat: Available 24/7 directly on the ajjl Platform. Our support team will route your enquiry to the Data Protection Officer where required.

ajjl will acknowledge all privacy-related enquiries within two (2) business days and aim to provide a substantive response within fifteen (15) calendar days. For complex data subject rights requests, this period may be extended by a further thirty (30) days where necessary, in which case we will notify you of the extension and the reason for the delay.

If you are not satisfied with ajjl's response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which supervises compliance with the Data Privacy Act of 2012.