vjll Privacy Policy

1. Who We Are

vjll operates the online gaming platform accessible at vjll.app, providing casino games, slots, bingo, live dealer games, and related services to Filipino players. For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), vjll acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players and visitors to the vjll platform.

This Privacy Policy applies to all personal data collected through the vjll website, mobile interface, customer support channels, and any other touchpoints through which you interact with vjll. By using the vjll platform, you acknowledge that you have read and understood this Privacy Policy.

2. Personal Data We Collect

vjll collects the following categories of personal data from players and platform visitors:

2.1 Registration and Identity Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Philippine mobile number
• Email address
• Username and encrypted password
• Residential address (city/province level, for KYC purposes)

2.2 Identity Verification (KYC) Data

• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID)
• Proof of address documents
• Selfie or facial image for identity verification purposes
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account)

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction records
• Payment method identifiers (e.g., GCash mobile number, bank account last four digits — full account numbers are not stored by vjll)
• Transaction amounts and timestamps
• Bonus and promotional credit history

2.4 Gameplay and Activity Data

• Game session records, including games played, bets placed, wins, and losses
• Responsible gaming tool usage (deposit limits set, self-exclusion requests)
• Login history, including timestamps and IP addresses
• Customer support interaction records

2.5 Technical and Device Data

• IP address and approximate geolocation (country/region level)
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Platform usage analytics (pages visited, features used, session duration)

3. How We Collect Your Data

vjll collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the vjll platform, including IP addresses, device identifiers, and usage analytics gathered through cookies and similar technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from security partners; payment confirmation data from GCash, PayMaya, and banking partners. vjll only receives data from third parties where you have authorised that sharing or where it is required by law.

4. Why We Use Your Personal Data

vjll uses your personal data for the following purposes:

• Account management: Creating and maintaining your vjll account, verifying your identity, and managing your login credentials.
• Service delivery: Processing deposits and withdrawals, crediting bonuses, providing access to games, and delivering customer support.
• Legal and regulatory compliance: Fulfilling KYC and Anti-Money Laundering (AML) obligations under Philippine law and PAGCOR regulations; maintaining transaction records as required by law; reporting to regulatory authorities where required.
• Fraud prevention and security: Detecting and preventing fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behaviour; administering self-exclusion and deposit limit tools; complying with PAGCOR responsible gaming requirements.
• Platform improvement: Analysing usage data to improve the vjll platform, fix technical issues, and develop new features that better serve Filipino players.
• Communications: Sending account-related notifications (e.g., deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about vjll offers and new games.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, vjll processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and vjll — i.e., to operate your account, process transactions, and deliver gaming services.
• Legal obligation: Processing required to comply with Philippine law, PAGCOR regulations, Anti-Money Laundering Act (AMLA) obligations, and other applicable legal requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for optional purposes such as marketing communications, where you have given explicit consent. You may withdraw consent at any time by contacting vjll support or updating your account preferences.

6. Sharing Your Personal Data

vjll does not sell, rent, or trade your personal data to third parties. vjll may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

6.1 Service Providers

vjll engages trusted third-party service providers to assist in operating the platform. These include KYC and identity verification providers, payment processing partners (GCash, PayMaya, and banking partners), fraud detection and cybersecurity providers, cloud hosting and infrastructure providers, and customer support platform providers. All service providers are contractually bound to process your data only on vjll's instructions and in accordance with applicable Philippine privacy law.

6.2 Regulatory and Law Enforcement Authorities

vjll may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), Philippine law enforcement agencies, or other competent authorities where required by law, court order, or regulatory directive. vjll will notify you of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of vjll's business, your personal data may be transferred to the acquiring entity as part of that transaction. vjll will notify affected players prior to any such transfer and ensure that the receiving entity is bound by privacy obligations no less protective than those in this Privacy Policy.

7. Cookies and Tracking Technologies

vjll uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse usage patterns. The following types of cookies are used on the vjll platform:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences such as language settings, game display options, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymised data about how players use the vjll platform, which pages are visited most frequently, and where technical errors occur. This data helps vjll improve the platform experience for Filipino players.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized login attempts.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the vjll platform. vjll does not use third-party advertising cookies or cross-site tracking technologies.

8. Data Security

vjll 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:

• SSL/TLS encryption for all data in transit between your device and vjll servers.
• AES-256 encryption for sensitive data stored at rest, including KYC documents and payment identifiers.
• Strict access controls ensuring that only authorised vjll personnel with a legitimate need can access player personal data.
• Regular security audits and penetration testing of the vjll platform infrastructure.
• Multi-factor authentication requirements for vjll staff accessing player data systems.
• Secure, geographically redundant data storage with regular encrypted backups.
• Incident response procedures to detect, contain, and notify affected players of any data breach in accordance with NPC requirements.

While vjll takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your vjll login credentials confidential and for notifying vjll immediately if you suspect unauthorized access to your account.

9. Data Retention

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

Upon expiry of the applicable retention period, vjll will securely delete or anonymise your personal data. Where data is anonymised rather than deleted, the anonymised data may be retained for statistical and analytical purposes without limitation, as it can no longer be linked to you as an individual.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by vjll:

• Right to be informed: You have the right to know what personal data vjll holds about you, how it is used, and with whom it is shared. This Privacy Policy fulfils that obligation.
• Right of access: You may request a copy of the personal data vjll holds about you. vjll will respond to access requests within fifteen (15) business days.
• Right to rectification: If any personal data vjll holds about you is inaccurate or incomplete, you have the right to request correction. You may update basic account details directly through your vjll account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to vjll's legal and regulatory retention obligations. Note that data subject to PAGCOR or AMLA retention requirements cannot be deleted before the mandatory retention period expires.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to vjll's overriding legal obligations.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to lodge a complaint: If you believe vjll has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact the vjll Data Privacy Officer using the contact details in Section 13 of this Policy. vjll may require you to verify your identity before processing a data subject rights request.

11. Children's Privacy and Age Restriction

The vjll platform is strictly intended for adults aged 21 years and above in accordance with PAGCOR regulations governing casino-style gaming in the Philippines. 21+

vjll does not knowingly collect personal data from individuals under the age of 21. If vjll becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended, the data will be deleted in accordance with applicable law, and the matter will be reported to PAGCOR.

Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gambling platforms. If you believe a minor has registered on vjll, please contact our support team immediately.

12. Updates to This Privacy Policy

vjll reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. The effective date at the top of this page will be updated whenever a material change is made.

Where changes are material, vjll will notify registered players via email or an in-platform notification prior to the changes taking effect. We encourage you to review this Privacy Policy periodically to stay informed about how vjll protects your personal data.

Your continued use of the vjll platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with any update, you may close your account by contacting vjll support.

13. Contact Our Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or vjll's handling of your personal data, please contact our Data Privacy Officer (DPO):

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.