a2jl Privacy Policy — How We Protect Your Personal Data

1. Overview and Scope

a2jl recognizes the fundamental right of every Filipino player to privacy and to the protection of their personal information. As a personal information controller under the Data Privacy Act of 2012 (Republic Act No. 10173), a2jl is responsible for determining the purposes and means of processing personal data collected through the a2jl platform. This Privacy Policy applies to all users of the a2jl platform, including registered account holders, visitors who browse the site without registering, and former account holders whose data is retained in accordance with applicable law.

This Policy covers all personal data collected from users located in the Philippines. It governs data collected directly from you during account registration and use, data collected automatically through your interaction with the a2jl platform, and data obtained from third parties where lawfully permitted. It does not apply to third-party websites or services that may be referenced in a2jl's platform, each of which operates under their own privacy practices.

2. Personal Data We Collect

2.1 Account Registration Data

When you register an a2jl account, we collect the following personal data:

• Full legal name as it appears on your government-issued Philippine identification document
• Date of birth (required to verify compliance with the 21+ age requirement under PAGCOR regulations)
• Registered Philippine mobile phone number used for account verification and security authentication
• Email address (where provided during registration)
• Account password (stored in encrypted, non-reversible form — a2jl staff cannot access your plaintext password)
• Preferred language and region settings

2.2 Identity Verification (KYC) Data

Philippine law requires a2jl to verify the identity of all users before processing withdrawal requests. To complete Know Your Customer (KYC) verification, we collect:

• Copies of government-issued Philippine photo identification (UMID, PhilSys National ID, Driver's License, Passport, or other PAGCOR-accepted documents)
• Proof of current residential address (utility bill, bank statement, or equivalent, issued within the last three months)
• Verification selfies or liveness check images, where requested for identity confirmation
• Source of funds declarations, where required by AML compliance obligations

2.3 Financial Transaction Data

To process deposits and withdrawals, a2jl collects and retains the following financial information:

• GCash or Maya account details associated with your a2jl account (mobile number registered to the e-wallet)
• Philippine bank account details provided for bank transfer withdrawals (account name, account number, and bank name)
• Transaction reference numbers, amounts, timestamps, and processing status for all deposits and withdrawals
• Gaming activity records including wager amounts, game outcomes, win/loss history, and account balance changes

2.4 Technical and Usage Data

When you access and use the a2jl platform, certain technical data is automatically collected:

• IP address and approximate geographic location derived from IP data
• Device type, operating system, and browser or application version
• Session duration, pages visited, features used, and navigation patterns within the a2jl platform
• Login timestamps and access history
• Cookies and similar tracking technologies (see Section 8)

2.5 Communications Data

When you contact a2jl customer support — whether through live chat, email, or any other channel — we retain records of your communications, including the content of messages, the nature of your query, and the resolution outcome. This data is used to improve service quality and resolve any recurring issues or disputes.

3. How Your Data Is Collected

a2jl collects personal data through the following methods:

• Direct collection: Data you provide voluntarily during account registration, KYC submission, cashier transactions, and customer support interactions
• Automated collection: Technical and usage data collected automatically through cookies, server logs, and analytics tools as you interact with the a2jl platform
• Third-party collection: Data received from payment processors (GCash, Maya, BPI, BDO, Metrobank, and others) confirming transaction status; identity verification service providers used during the KYC process; and fraud detection or AML screening services as required by Philippine regulatory obligations

4. How a2jl Uses Your Personal Data

a2jl processes your personal data for the following lawful purposes, each of which is grounded in at least one recognized legal basis under the Data Privacy Act of 2012:

4.1 Account Management and Service Delivery

We use your registration and identity data to create and maintain your a2jl account, authenticate your identity upon login, enable you to deposit and withdraw funds, provide access to all gaming products on the a2jl platform, and communicate with you about your account status and transactions. This processing is necessary for the performance of the contract between you and a2jl.

4.2 Regulatory Compliance

a2jl is legally required to verify the age and identity of all registered players, maintain transaction records for anti-money laundering (AML) compliance purposes, report suspicious transactions to the appropriate Philippine authorities as required by the Anti-Money Laundering Act (Republic Act No. 9160, as amended), and retain gaming and financial records for the minimum period required by applicable law. This processing is carried out in compliance with a legal obligation binding on a2jl.

4.3 Responsible Gaming Compliance

a2jl uses your gaming activity data, deposit history, and account behavior data to monitor for signs of problem gambling behavior, enforce deposit limits and self-exclusion requests you have activated, verify compliance with the 21+ age requirement, and ensure that players on any self-exclusion register are not permitted to access the a2jl platform. This processing is carried out to protect the vital interests of our users and in compliance with PAGCOR responsible gaming requirements.

4.4 Fraud Prevention and Security

We process your technical and usage data, combined with account activity patterns, to detect and prevent fraudulent account activity, money laundering, bonus abuse, and unauthorized access to a2jl accounts. This processing is necessary for the legitimate interests of a2jl in maintaining a secure and fair gaming environment for all Filipino players.

4.5 Platform Improvement and Analytics

Aggregated and anonymized usage data is used to understand how Filipino players interact with the a2jl platform, identify areas where the user experience can be improved, and optimize platform performance for Philippine mobile networks and devices. This processing uses anonymized or pseudonymized data that does not identify individual users.

4.6 Marketing Communications

Where you have provided explicit consent to receive promotional communications, a2jl may use your contact details to notify you of bonuses, promotions, and new platform features relevant to your gaming interests. You may withdraw your consent to receive marketing communications at any time by contacting a2jl customer support or by using the unsubscribe function in any marketing message we send. Withdrawal of marketing consent does not affect a2jl's right to send you service-related account notifications.

5. Sharing of Personal Data

a2jl does not sell, rent, or trade your personal data to any third party for commercial purposes. We share your personal data only in the following limited and lawful circumstances:

• Payment processors: GCash, Maya, InstaPay, PesoNet, BPI, BDO, Metrobank, and other payment partners receive only the minimum data necessary to process your specific transaction (typically your registered mobile number or bank account details)
• Identity verification providers: KYC and document verification service providers process identity documents on behalf of a2jl for the sole purpose of verifying your identity in compliance with Philippine law
• Regulatory authorities: a2jl discloses data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and other Philippine regulatory bodies where required by law, court order, or legitimate regulatory request
• Fraud prevention services: Data may be shared with industry fraud prevention networks to detect and prevent account fraud, in anonymized or pseudonymized form where possible
• IT and platform infrastructure providers: Technical service providers that host or support the a2jl platform may process data on our behalf, subject to contractual data processing agreements that bind them to the same data protection standards applied by a2jl

6. Data Retention

a2jl retains your personal data for the period necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and identity data: Retained for a minimum of 5 years following account closure, as required by AML regulations
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction
• Gaming activity records: Retained for a minimum of 3 years from the date of the gaming session
• Customer support communications: Retained for 2 years from the date of the interaction
• KYC documents: Retained for a minimum of 5 years following account closure or last transaction, whichever is later

After the applicable retention period has expired, a2jl will securely delete or anonymize your personal data unless retention is required by a continuing legal obligation, active regulatory inquiry, or ongoing dispute resolution process.

7. Data Security Measures

a2jl implements technical and organizational measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit TLS encryption for all data transmitted between your device and the a2jl platform
• Encryption at rest for stored personal data, financial records, and identity documents
• Multi-factor authentication options for a2jl account access
• Strict access controls limiting internal access to personal data on a need-to-know basis
• Regular security assessments and vulnerability testing of the a2jl platform
• Staff training on data privacy obligations under Philippine law

While a2jl takes all reasonable precautions to protect your data, no online platform can guarantee absolute security against all possible threats. You share responsibility for protecting your a2jl account by maintaining the confidentiality of your login credentials and reporting any suspected unauthorized access to a2jl immediately.

8. Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files stored on your device when you visit the a2jl platform. They allow the platform to recognize your device across sessions, remember your preferences, and maintain your login session securely.

8.2 Types of Cookies Used by a2jl

• Strictly necessary cookies: Required for basic platform functionality including user authentication, session management, and security. These cannot be disabled without impairing platform access.
• Functional cookies: Store your language preferences, display settings, and other personalization choices to improve your a2jl experience across sessions.
• Analytics cookies: Collect anonymized usage data that helps a2jl understand how players navigate the platform and identify areas for improvement. No personally identifiable information is transmitted through analytics cookies.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and account takeover attempts.

8.3 Managing Cookies

You may control or disable non-essential cookies through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging into your a2jl account and using core platform features. Instructions for managing cookies are available in the help section of your browser.

9. Your Data Privacy Rights Under Philippine Law

As a data subject under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by a2jl:

• Right to be informed: You have the right to know how your personal data is collected, processed, and used by a2jl — which is the purpose of this Privacy Policy.
• Right to access: You may request a copy of the personal data that a2jl holds about you by contacting our customer support team.
• Right to correction: If any personal data held by a2jl is inaccurate, incomplete, or outdated, you may request that it be corrected. Some corrections may require submission of supporting documentation.
• Right to erasure: Subject to applicable legal retention obligations (see Section 6), you may request the deletion of your personal data. Note that data subject to AML or regulatory retention requirements cannot be deleted before the applicable retention period has expired.
• Right to data portability: You may request your personal data in a structured, commonly used, and machine-readable format for transfer to another service, where technically feasible.
• Right to object: You may object to the processing of your personal data for marketing purposes at any time. You may also object to other forms of processing where legitimate interests are the stated legal basis, subject to a2jl's overriding legitimate interests or legal obligations.
• Right to complain: If you believe a2jl has violated your data privacy rights, you may file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, contact a2jl customer support via live chat or at [email protected]. We will respond to all data privacy requests within 15 business days of receipt, in accordance with NPC guidelines.

10. Protection of Minors

The a2jl platform is strictly restricted to individuals who are 21 years of age or older, in compliance with PAGCOR regulations governing online gaming in the Philippines. a2jl does not knowingly collect personal data from individuals under 21 years of age. If a2jl discovers that personal data has been collected from a person under the age of 21, that account will be immediately closed, all associated data will be deleted (subject to any AML retention obligations), and any deposited funds will be returned to the originating payment account.

11. Cross-Border Data Transfers

Certain technical service providers and platform infrastructure components used by a2jl may process or store data in locations outside the Republic of the Philippines. In such cases, a2jl ensures that appropriate safeguards are in place — including contractual data processing clauses, data transfer agreements, or transfers to jurisdictions recognized by the National Privacy Commission as providing adequate data protection. No cross-border transfer of your personal data is made unless a2jl has verified that adequate protections are in place to meet the standards required by the Data Privacy Act of 2012.

12. Changes to This Privacy Policy

a2jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, updates to Philippine law, or changes to the a2jl platform. Where changes are material, a2jl will provide reasonable notice to registered users via on-site notification or by email to the address associated with your a2jl account, prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the a2jl platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. We recommend reviewing this Policy periodically to stay informed of how a2jl handles your personal data.

13. Contact and Data Privacy Officer

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by a2jl, please contact our Data Privacy Officer via:

• Email: [email protected] (mark your subject line "Data Privacy Request")
• Live Chat: Available 24/7 through the a2jl platform

a2jl aims to respond to all data privacy inquiries within 15 business days. For complaints that cannot be resolved directly with a2jl, you may contact the National Privacy Commission of the Philippines, the independent regulatory body responsible for enforcing Republic Act No. 10173.