Privacy Policy

Introduction

vjl Casino ("vjl," "we," "us," "our") operates the online casino and sports betting platform accessible at vjl.bet (the "Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information belonging to Platform users ("you," "your," "User") and website visitors.

vjl Casino is committed to complying with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), the National Privacy Commission's ("NPC") issuances, and the data protection requirements imposed by PAGCOR as a condition of vjl's e-gaming license. This Policy is drafted to be consistent with all applicable Philippine data protection law.

By registering for a vjl Account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal information as described herein. Where processing is based on consent, you retain the right to withdraw that consent at any time, subject to the limitations described in Section 13.

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, vjl Casino is the Personal Information Controller ("PIC") in respect of all personal data collected from users of the Platform. As PIC, vjl Casino determines the purposes and means of processing your personal information and bears the obligations imposed on controllers under the DPA and its IRR.

vjl Casino has appointed a Data Protection Officer ("DPO") responsible for overseeing the Platform's data protection compliance, handling data subject requests, and liaising with the National Privacy Commission where required. Contact details for the DPO are provided in Section 16 of this Policy.

Certain data processing activities — including payment processing, game system operation, and customer relationship management — are carried out by third-party Personal Information Processors ("PIPs") acting on vjl's instruction under data processing agreements that impose data protection obligations equivalent to those required by the DPA. The identities of material PIPs are disclosed in Section 7.

Personal Data We Collect

vjl Casino collects the following categories of personal data in connection with the operation of the Platform:

vjl Casino does not intentionally collect sensitive personal information as defined under Section 3(l) of the DPA — including information about race, ethnicity, health, sexual orientation, or political beliefs — except where the provision of such information is initiated by the data subject (for example, in a responsible gaming self-assessment context). Where sensitive personal information is incidentally collected, it is handled with the heightened protections required by the DPA.

How We Collect Personal Data

vjl Casino collects personal data through the following methods:

• Direct Collection: Information you provide during account registration, KYC document submission, deposit and withdrawal requests, customer support interactions, and any completion of Platform forms.
• Automated Collection: Technical data collected automatically as you access and use the Platform, including through server logs, session tracking, and cookie and similar tracking technologies described in Section 11.
• Payment Processor Data: Confirmation and reference data received from GCash, Maya, BPI, BDO, UnionBank, and other payment processors when you initiate financial transactions on the Platform. vjl does not receive or store raw payment credentials — full card numbers and GCash PINs are processed exclusively by the respective payment provider.
• Third-Party Game Providers: Game session and outcome data generated within third-party game environments integrated into the vjl Platform. Such data is shared back to vjl for wallet settlement, RTP verification, and regulatory reporting purposes.
• Verification Providers: Identity verification results from KYC service providers used to confirm the accuracy of government ID submissions and age verification.

Legal Basis for Processing

vjl Casino processes personal data on the following legal bases as recognised under the DPA and its IRR:

• Performance of Contract: Processing necessary to establish and maintain your vjl Account, process deposits and withdrawals, deliver gameplay, calculate and award bonuses, and provide customer support. Without this processing, vjl cannot provide the services you have contracted for.
• Legal Obligation: Processing required to comply with vjl's obligations under PAGCOR's e-gaming licensing conditions, the Anti-Money Laundering Act (Republic Act No. 9160, as amended), the Terrorism Financing Prevention and Suppression Act, and any other applicable Philippine law. This includes KYC verification, transaction monitoring, and regulatory reporting.
• Legitimate Interest: Processing necessary for vjl's legitimate operational interests, including fraud prevention, platform security, technical performance monitoring, and responsible gaming compliance — provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications and non-essential analytics, where you have provided explicit, freely given, specific, and informed consent. You may withdraw marketing consent at any time through Account Settings without affecting the lawfulness of prior processing.

How We Use Your Personal Data

vjl Casino uses the personal data it collects for the following purposes:

6.1 Account Operations

Creating, maintaining, and managing your vjl Account; processing your login and authentication; enforcing the one-account-per-person rule; managing your PHP Wallet balance; processing deposit and withdrawal requests; and communicating account-related notifications including transaction confirmations and security alerts.

6.2 Regulatory Compliance

Fulfilling KYC and age verification obligations mandated by PAGCOR; conducting transaction monitoring and suspicious activity reporting as required by Philippine AML law; maintaining records of gaming activity and financial transactions for the minimum retention periods specified by PAGCOR and the AMLC; and responding to lawful requests from PAGCOR, the AMLC, and other competent Philippine regulatory and law enforcement authorities.

6.3 Responsible Gaming

Administering deposit limits, session timers, self-exclusion orders, and other responsible gaming tools; monitoring gaming patterns to identify indicators of potential problem gambling behaviour in accordance with PAGCOR's responsible gaming requirements; and enforcing the Platform's 21+ age restriction.

6.4 Fraud Prevention and Security

Detecting and investigating fraudulent activity, including duplicate account creation, bonus abuse, and collusion; monitoring login activity for unauthorized access indicators; maintaining Platform security and integrity; and investigating disputes or complaints.

6.5 Platform Improvement

Analysing aggregated and anonymised usage data to improve Platform performance, game library curation, mobile optimization, and user experience; troubleshooting technical issues; and conducting internal research and analytics.

6.6 Marketing and Promotions

Where you have provided consent, sending promotional communications about vjl Casino offers, new games, bonuses, and events via SMS, email, or in-Platform notifications. You may opt out of marketing communications at any time through Account Settings.

Data Sharing and Disclosure

vjl Casino does not sell, rent, or otherwise commercially transfer your personal data to third parties for their own marketing purposes. Personal data is shared with third parties only in the following circumstances:

• Payment Processors: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, UnionBank, and other licensed financial institutions — for the purpose of processing your deposit and withdrawal transactions. These entities are independently regulated by the Bangko Sentral ng Pilipinas and have their own data protection obligations.
• Game Providers: Certified third-party game software providers integrated into the vjl Platform (including but not limited to JILI Games, PG Soft, and Pragmatic Play) — limited to the session and outcome data necessary for game delivery and wallet settlement.
• KYC and Verification Providers: Identity verification service providers engaged to assist with government ID authentication and age verification, acting as Personal Information Processors under data processing agreements with vjl.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government agencies — where disclosure is required by law, regulation, court order, or valid legal process.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by vjl — under obligations of professional confidentiality and, where applicable, data processing agreements.
• Business Transfers: In the event of a merger, acquisition, or sale of vjl Casino's business or assets, personal data may be transferred to the acquiring entity, provided the acquiring entity assumes data protection obligations no less protective than those in this Policy.

International Data Transfers

Certain third-party game providers and technology vendors engaged by vjl Casino process data on servers located outside the Philippines. Where personal data is transferred to recipients in countries that may not provide the same level of data protection as Philippine law, vjl Casino implements contractual safeguards — including standard data protection clauses — to ensure that your personal information remains protected to a standard consistent with the DPA.

vjl Casino does not transfer personal data internationally unless: (a) the transfer is to a country recognised by the NPC as providing adequate data protection; (b) appropriate contractual safeguards are in place; or (c) the transfer is necessary for the performance of your Account contract (for example, game session data processed by a provider's servers) and you have been informed of the transfer through this Policy.

Data Retention

vjl Casino 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 imposed by Philippine law and PAGCOR regulations:

• KYC and Identity Documents: Minimum five (5) years from the date of account closure, as required by PAGCOR's e-gaming licensing conditions and Philippine AML regulations.
• Financial Transaction Records: Minimum five (5) years from the date of transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Gaming Activity Records: Minimum two (2) years from the date of the gaming session, or such longer period as specified by PAGCOR's applicable circular.
• Customer Support Communications: Two (2) years from the date of the last communication, unless the communication relates to an unresolved dispute or regulatory matter.
• Marketing Preferences and Consent Records: Duration of the account relationship, plus three (3) years following account closure to evidence consent compliance.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with vjl Casino's data disposal procedures. Anonymised data that no longer identifies or is linkable to any individual may be retained indefinitely for analytical purposes.

Security Measures

vjl Casino implements technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit Transport Layer Security (TLS) encryption for all data transmitted between your device and the vjl Platform.
• Encryption at rest for sensitive personal data including government ID records, financial data, and authentication credentials.
• Password hashing using industry-standard cryptographic algorithms — vjl does not store plaintext passwords.
• Role-based access controls limiting staff access to personal data to those with a documented operational need.
• Multi-factor authentication requirements for all staff accessing systems containing personal data.
• Regular security assessments, penetration testing, and vulnerability management.
• Data breach detection, response, and notification procedures consistent with NPC Circular No. 16-03 requirements.

No information security system can guarantee absolute protection against all threats. In the event of a personal data breach that is likely to result in a real risk of harm to affected individuals, vjl Casino will notify the affected individuals and the National Privacy Commission within 72 hours of becoming aware of the breach, in accordance with applicable NPC requirements.

Cookies and Tracking Technologies

vjl Casino uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly Necessary Cookies: Session management, authentication state persistence, security tokens, and Platform functionality. These cookies cannot be disabled without rendering the Platform non-functional.
• Performance Cookies: Aggregated, anonymised analytics data used to understand how users interact with the Platform — including page load times, game loading performance, and navigation patterns. This data informs technical optimisation decisions.
• Functional Cookies: Preference settings such as your chosen language, responsible gaming reminder intervals, and display preferences.
• Marketing Cookies (Consent Required): Where you have consented, cookies that enable vjl to deliver relevant promotional content within the Platform and measure the effectiveness of promotional campaigns.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to access the core Platform, but may affect personalisation features and the relevance of in-Platform promotions. vjl Casino does not currently use third-party advertising cookies or cross-site tracking technologies.

Children's Privacy — 21+ Strictly Enforced

vjl Casino's services are strictly restricted to individuals aged 21 years and older, as mandated by PAGCOR regulations governing casino-style gambling in the Philippines. The Platform is not directed at, and does not knowingly collect personal data from, individuals under 21 years of age.

Age is verified through KYC document submission during the account registration process. Where vjl Casino discovers or is notified that personal data has been collected from an individual under the age of 21, that account will be permanently closed, any winnings will be forfeited, and the personal data will be deleted or retained solely for the purpose of complying with the mandatory reporting obligation to PAGCOR, as required by regulation.

If you believe that vjl Casino may have inadvertently collected personal data from an underage individual, please contact our Data Protection Officer immediately at the details provided in Section 16.

Exercising Your Data Rights

To exercise any of the data rights described in the opening section of this Policy — including rights of access, rectification, erasure, objection, or portability — please submit a request to vjl Casino's Data Protection Officer using the contact details in Section 16. All requests must include:

• Your full legal name and the email address or mobile number registered to your vjl Account.
• A clear description of the right you wish to exercise and the specific data it concerns.
• A copy of a valid Philippine government-issued ID for identity verification.

vjl Casino will acknowledge receipt of your request within 5 business days and provide a substantive response within 15 business days. Complex requests may require up to 30 business days, in which case vjl will notify you of the extended timeline within the initial 15-day period.

Requests for erasure or restriction of processing will be assessed against vjl's legal retention obligations. Where retention is required by PAGCOR, AML regulations, or other Philippine law, erasure will not be possible for the duration of the applicable retention period, and vjl will inform you of this outcome and the reason for it.

Complaints and Regulatory Escalation

If you are dissatisfied with how vjl Casino has handled your personal data or responded to a data rights request, you are entitled to file a complaint with the National Privacy Commission of the Philippines. The NPC is the statutory body responsible for enforcing the Data Privacy Act of 2012 and has jurisdiction over complaints against Personal Information Controllers operating in the Philippines.

Before escalating to the NPC, vjl Casino encourages you to contact our Data Protection Officer directly — most data protection concerns can be resolved faster through our internal process than through formal regulatory proceedings. vjl's DPO will treat all complaints with priority and confidentiality.

Amendments to This Privacy Policy

vjl Casino may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or business operations. Material changes — including changes to the purposes for which we process your personal data, the categories of data we collect, or the third parties with whom we share data — will be communicated to registered Users via email to the address on file, with a minimum of 14 days' notice before the change takes effect.

Non-material updates, including typographical corrections and clarifications that do not alter the substantive data protection rights described herein, may be made without advance notice. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision.

Your continued use of the Platform following the effective date of a revised Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree to the revised Policy, you should cease using the Platform and request account closure before the effective date.

Data Protection Officer — Contact Details

vjl Casino's Data Protection Officer is the designated point of contact for all matters relating to personal data protection, including data rights requests, privacy complaints, and regulatory inquiries. The DPO can be reached through the following channels:

For inquiries specifically related to PAGCOR regulatory compliance, vjl Casino's PAGCOR licensing details are documented on the About Us page of this Platform.