jolino1 Privacy Policy

1 Scope & Application

This Privacy Policy applies to all personal information collected, stored, processed, and used by jolino1 ("we", "us", "our") in connection with the operation of the jolino1 online casino and sports betting platform, accessible at jolino1.net and any associated mobile applications or sub-domains (collectively, the "Platform").

This Policy applies to all individuals who interact with the Platform, including:

• Registered players with active jolino1 accounts.
• Visitors who browse the jolino1 website without registering.
• Individuals who contact jolino1 customer support via email or live chat.
• Individuals who participate in jolino1 promotions, surveys, or feedback programs.

This Privacy Policy is governed by and construed in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC). Where applicable, this Policy is also read in conjunction with PAGCOR's data handling requirements for licensed gaming operators.

2 Personal Data We Collect

jolino1 collects the following categories of personal information, depending on how you interact with the Platform:

jolino1 does not intentionally collect sensitive personal information (as defined under RA 10173, such as health data, political opinions, or religious beliefs) unless explicitly required for a specific regulatory purpose and with your prior consent.

3 How We Use Your Personal Data

jolino1 uses the personal information we collect for the following specific, legitimate purposes:

1. Account Management: To create, maintain, and administer your jolino1 player account, including processing registrations, managing account settings, and verifying your identity (KYC) as required before processing withdrawals.
2. Payment Processing: To facilitate deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, including verifying that payment accounts are registered in your name and detecting potentially fraudulent transactions.
3. Gaming Services: To deliver, personalize, and improve the jolino1 gaming experience — including slot games, live dealer games, bingo, Super Wheel, 3 Gods Fishing, and sports betting. This includes processing bets, calculating winnings, and maintaining accurate game logs.
4. Regulatory Compliance: To comply with Philippine Anti-Money Laundering Act (AMLA) obligations, PAGCOR licensing requirements, NPC data privacy regulations, and any other applicable legal obligation, including reporting requirements to the Anti-Money Laundering Council (AMLC).
5. Security & Fraud Prevention: To detect, investigate, and prevent fraudulent account activity, multi-accounting, bonus abuse, unauthorized access, and other prohibited conduct as defined in our Terms and Conditions.
6. Responsible Gaming: To monitor gaming patterns for indicators of problem gambling and to administer self-exclusion, deposit limits, session time reminders, and other responsible gaming tools at your request or as required by our regulatory obligations.
7. Customer Support: To respond to your support inquiries, complaints, and feedback submitted to the jolino1 support team at [email protected].
8. Marketing Communications: To send you information about jolino1 promotions, bonuses, and new game launches, where you have given consent to receive such communications. You may opt out at any time by contacting our support team.
9. Platform Improvement: To analyze aggregated, anonymized usage data to improve platform performance, game selection, and the overall player experience on jolino1.

jolino1 will not use your personal data for any purpose not described in this Privacy Policy without first notifying you and, where required by law, obtaining your consent.

4 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, jolino1 relies on the following legal bases when processing your personal information:

• Contractual Necessity: Processing required to fulfill our contractual obligations to you under the jolino1 Terms and Conditions — including account management, payment processing, and delivery of gaming services.
• Legal Obligation: Processing required to comply with applicable Philippine law, including AMLA reporting obligations, PAGCOR licensing requirements, and NPC data privacy regulations.
• Legitimate Interest: Processing conducted for jolino1's legitimate business interests where these interests are not overridden by your privacy rights — including fraud detection, security monitoring, and platform improvement based on anonymized analytics.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for optional marketing communications. You may withdraw consent for marketing at any time without affecting the legality of processing carried out prior to withdrawal.

5 Sharing Your Personal Data

jolino1 does not sell, rent, trade, or otherwise transfer your personal information to third parties for their independent commercial purposes. We may share your personal data only in the following circumstances and only to the extent strictly necessary:

1. Payment Service Providers: GCash, PayMaya, BPI, BDO, and Metrobank, and their respective payment processing infrastructure partners, solely to facilitate your deposits and withdrawals.
2. KYC & Identity Verification Partners: Third-party identity verification service providers engaged by jolino1 to perform document verification and age confirmation as part of our mandatory KYC process.
3. Game Technology Providers: Third-party game studios and software providers whose games are integrated into the jolino1 platform. These providers may receive anonymized session data required to operate their games correctly. They do not receive your full identity or financial information.
4. Regulatory Authorities: Philippine government agencies and regulatory bodies, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement authorities, where jolino1 is legally required to disclose your information.
5. Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by jolino1 under strict confidentiality obligations.
6. Business Transfers: In the event of a merger, acquisition, or sale of jolino1 or its assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified prior to any such transfer.

All third parties with whom jolino1 shares personal data are contractually required to maintain appropriate data security measures and to use your data only for the specified purpose for which it was shared.

6 Cookies & Tracking Technologies

jolino1 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the jolino1 website. Cookies help us recognize returning players, maintain session security, and understand how players navigate the platform.

The types of cookies used by jolino1 include:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in while you navigate between pages. These cookies cannot be disabled without impairing your ability to use jolino1.
• Functional Cookies: Remember your preferences (such as language and display settings) to provide a more personalized experience on jolino1.
• Analytics Cookies: Collect anonymized information about how players use the Platform — which games are most popular, how long sessions last, and which pages players visit most frequently. This data is used in aggregate only and cannot be used to identify you personally.
• Security Cookies: Used to detect and prevent fraudulent activity, multiple account registrations from the same device, and unauthorized access attempts.

You may control cookie settings through your browser preferences. Note that disabling strictly necessary cookies will prevent you from logging in to your jolino1 account. jolino1 does not use third-party advertising cookies or behavioral tracking cookies for cross-site advertising purposes.

7 Data Security

jolino1 implements a comprehensive set of technical and organizational security measures to protect your personal information against unauthorized access, loss, destruction, alteration, or disclosure. These measures include:

• Encryption in Transit: All data transmitted between your device and jolino1 servers is encrypted using TLS 1.2 or higher (HTTPS). This protects your login credentials, payment details, and personal information from interception.
• Encryption at Rest: Sensitive data stored in jolino1 databases — including passwords (stored as hashed values, never in plain text), financial account details, and government ID information — is encrypted using AES-256 or equivalent standards.
• Access Controls: Strict role-based access controls ensure that jolino1 staff can only access player data that is necessary for their specific job function. Access to financial and identity data is restricted to authorized compliance and payments personnel only.
• Two-Factor Authentication: jolino1 offers and strongly recommends two-factor authentication (2FA) for all player accounts to prevent unauthorized access even if login credentials are compromised.
• Regular Security Audits: jolino1 conducts periodic security assessments, penetration testing, and vulnerability scans to identify and remediate potential weaknesses in our data infrastructure.
• Incident Response: jolino1 maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights, jolino1 will notify the NPC and affected players in accordance with the timelines prescribed by the Data Privacy Act of 2012.

8 Data Retention

jolino1 retains personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable Philippine law and PAGCOR regulatory requirements. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be linked to any individual player. Anonymized, aggregated data may be retained indefinitely for statistical and platform improvement purposes.

9 Your Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173), all Filipino data subjects — including jolino1 players — hold the following rights with respect to their personal information:

1. Right to Be Informed: You have the right to be informed about how jolino1 collects and uses your personal information — which is the purpose of this Privacy Policy.
2. Right of Access: You may request a copy of the personal information jolino1 holds about you at any time. jolino1 will respond to verified access requests within 15 business days.
3. Right to Correction: You may request that inaccurate, incomplete, or outdated personal information held by jolino1 be corrected or updated. Basic account details (name, contact number, email) can also be updated directly from your account settings.
4. Right to Erasure / Blocking: You may request the deletion or blocking of your personal information where it is no longer necessary for the purposes for which it was collected, or where processing is unlawful. This right is subject to jolino1's legal and regulatory retention obligations under AMLA and PAGCOR requirements.
5. Right to Object: You may object to the processing of your personal information for direct marketing purposes at any time. You may also object to processing based on legitimate interest, subject to overriding legal grounds.
6. Right to Data Portability: Where technically feasible, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
7. Right to Lodge a Complaint: If you believe jolino1 has processed your personal data in violation of the Data Privacy Act of 2012, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request". Please include your full name, registered email address, and a description of your request. jolino1 may request additional identity verification before processing your request.

10 Children & Minors

jolino1 is strictly an adult gaming platform. Access to and use of the jolino1 platform is prohibited for any person under 21 years of age, in accordance with PAGCOR regulations governing online gaming in the Philippines.

jolino1 does not knowingly collect personal information from anyone under 21 years of age. If we become aware that a player account has been registered by a person under the age of 21, we will:

• Immediately and permanently close the account.
• Delete all personal information associated with the account in accordance with applicable law.
• Handle any funds in the account in accordance with PAGCOR regulations and applicable Philippine law.
• Report the incident to the relevant regulatory authorities where required.

11 Cross-Border Data Transfers

jolino1 is a platform built for Filipino players, and the majority of data processing occurs within the Philippines or within jurisdictions that maintain data protection standards comparable to RA 10173. Where it is necessary to transfer personal data outside the Philippines — for example, to third-party game providers or technology infrastructure partners with servers in other countries — jolino1 ensures that:

• The receiving country or organization provides an adequate level of protection for personal data, as assessed under the standards of the National Privacy Commission.
• Appropriate contractual safeguards (including Data Processing Agreements and Standard Contractual Clauses) are in place between jolino1 and the receiving party.
• The transfer is limited to the minimum data necessary for the specific, disclosed purpose.
• You are notified of any cross-border transfer where required by NPC regulations.

jolino1 does not transfer your financial account details (GCash, PayMaya, bank account numbers) outside the Philippines under any circumstances, except as strictly required for payment processing by the relevant Philippine payment service provider.

12 Updates to This Privacy Policy

jolino1 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, new features on the Platform, updates to Philippine privacy law, or changes in PAGCOR regulatory requirements.

When material changes are made to this Privacy Policy, jolino1 will:

• Notify registered players via email to their registered jolino1 email address.
• Display a prominent notice on the jolino1 website for a reasonable period prior to the changes taking effect.
• Update the "Last Updated" date at the top of this page.

Continued use of the jolino1 Platform after the effective date of an updated Privacy Policy constitutes acceptance of the updated terms. If you do not agree with a material change to this Privacy Policy, you have the right to close your jolino1 account and request deletion of your personal data (subject to our legal retention obligations) by contacting [email protected] prior to the effective date.

13 Contact & Data Protection Officer

jolino1 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and all NPC issuances. If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by jolino1, please contact our Data Protection Officer using the details below:

jolino1 will acknowledge all data privacy requests within 3 business days and will endeavor to resolve requests within 15 business days. For complex requests, we may require up to 30 business days, in which case we will notify you of the extended timeline.

If you are not satisfied with jolino1's response to your data privacy request or complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines.