a2jl Privacy Policy

Section 1

Identity of the Data Controller

The data controller responsible for your personal information processed through the a2jl Platform is the operator of a2jl.net. For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, a2jl acts as the Personal Information Controller (PIC) in relation to all personal data collected from registered players and website visitors.

As Personal Information Controller, a2jl determines the purposes for which, and the means by which, your personal data is processed. a2jl has appointed a Data Protection Officer (DPO) who can be contacted at the details set out in Section 15 of this Policy.

Section 2

Data We Collect

a2jl collects the following categories of personal information from players and platform users:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification — players must be 21 years or older);
• Residential address, including barangay, city or municipality, province, and postal code;
• Philippine mobile number and email address;
• Nationality and country of residence.

2.2 Identity Verification (KYC) Data

• Government-issued photo identification document (e.g., PhilSys National ID, passport, driver's license, UMID, SSS ID, PRC ID, or Voter's ID);
• Proof of address documentation;
• Selfie photograph taken at the time of KYC submission;
• Source of funds documentation, where required for compliance purposes.

2.3 Financial Data

• GCash account number or Maya account details;
• Bank account details (BPI, BDO, UnionBank, Metrobank, Landbank, or other linked institutions);
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment references;
• Cryptocurrency wallet addresses where applicable (USDT transactions).

2.4 Gaming Activity Data

• Game session history, including game titles played, wager amounts, outcomes, and timestamps;
• Bonus and promotion redemption records;
• Loyalty points balance and tier progression history;
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion records).

2.5 Technical & Device Data

• IP address and approximate geolocation at the time of each login;
• Device type, operating system, and browser type;
• Login timestamps, session durations, and access logs;
• Cookie identifiers and similar tracking technologies (see Section 6).

2.6 Communications Data

• Records of your communications with a2jl's customer support team, including live chat transcripts and email correspondence;
• Feedback, complaints, and dispute records.

Section 3

How We Collect Your Data

a2jl collects personal data through the following channels:

• Direct submission: Information you provide when registering an Account, completing KYC verification, making deposits, requesting withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the a2jl Platform, through server logs, cookies, and similar technologies;
• Third-party sources: Identity verification data from KYC service providers; payment data from payment processors (GCash, Maya, BPI, BDO, and others); fraud detection data from anti-fraud service providers;
• Publicly available sources: Publicly accessible information used for compliance checks, such as government sanction lists and adverse media screening.

Section 4

Legal Basis for Processing

a2jl processes your personal data on the following lawful bases under the Data Privacy Act of 2012:

Section 5

How We Use Your Data

a2jl uses the personal data we collect for the following purposes:

• To create, verify, manage, and maintain your a2jl Account;
• To verify your identity and age in compliance with PAGCOR and Data Privacy Act requirements;
• To process deposits, withdrawals, and other financial transactions through GCash, Maya, bank transfer, and other payment channels;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To personalize your gaming experience, including game recommendations, promotional offers, and loyalty tier management;
• To provide customer support and resolve complaints or disputes;
• To monitor gaming activity for responsible gaming indicators and to administer self-exclusion and limit tools;
• To send transactional communications (account confirmations, withdrawal notifications, security alerts);
• To send marketing communications where you have opted in to receive them;
• To analyze platform usage, improve the a2jl service, and develop new features;
• To comply with our legal and regulatory obligations under Philippine law.

Section 6

Cookies & Tracking Technologies

a2jl uses cookies and similar tracking technologies on the Platform to enhance functionality, analyze usage, and deliver a better experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. They enable core features such as account login sessions, game loading, and security measures. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings, display preferences, and saved game history. Disabling these may affect Platform functionality.
• Analytics Cookies: Used to understand how players navigate the Platform — which pages are visited most, where drop-offs occur, and how features are used. This data is aggregated and anonymized.
• Session Integrity Cookies: Used to detect and prevent fraudulent sessions, account takeover attempts, and abnormal access patterns.

Section 7

Sharing Your Personal Data

a2jl does not sell, rent, or trade your personal information to third parties for their own marketing purposes. Your data may be shared with the following categories of recipients, strictly on a need-to-know basis:

• Game Providers: Third-party game software suppliers (e.g., Evolution Gaming, Pragmatic Play, SA Gaming) receive limited technical session data necessary to operate games on our Platform. They are bound by contractual data protection obligations.
• Payment Processors: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, UnionBank, and other payment service providers receive necessary financial data to process your transactions.
• KYC & Identity Verification Providers: Third-party identity verification services receive your submitted identification documents to perform automated and manual verification checks.
• Fraud & AML Compliance Providers: Anti-fraud and anti-money laundering screening services receive limited personal data necessary to screen against sanction lists and detect suspicious activity.
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other relevant Philippine regulatory bodies may receive your data when required by law or regulatory directive.
• Legal and Professional Advisors: Legal counsel, auditors, and compliance consultants may access personal data under strict confidentiality obligations where necessary to provide services to a2jl.
• Law Enforcement: Where a2jl is legally required or compelled by a valid court order or law enforcement directive to disclose personal data, we will do so after verifying the legal basis for such a request.

All third parties with whom a2jl shares personal data are required to handle it in accordance with applicable data protection law and are prohibited from using it for purposes other than those specified in their agreements with a2jl.

Section 8

Data Retention

a2jl retains personal data for the periods necessary to fulfill the purposes for which it was collected, and in compliance with applicable Philippine legal and regulatory requirements. The following general retention guidelines apply:

Upon expiry of the applicable retention period, a2jl will securely destroy, delete, or anonymize your personal data using industry-standard data destruction procedures.

Section 9

Data Security Measures

a2jl implements technical, organizational, and procedural security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Encryption: All data transmitted between your device and a2jl servers is encrypted using TLS 1.3. Personal and financial data at rest is encrypted using AES-256;
• Access Controls: Access to personal data is restricted to a2jl personnel who have a specific, role-based need. Access rights are reviewed periodically and revoked when no longer required;
• Two-Factor Authentication: Internal systems holding personal data require multi-factor authentication for all access;
• Penetration Testing: a2jl conducts regular security assessments and penetration tests on its infrastructure to identify and remediate vulnerabilities;
• Incident Response: a2jl maintains a data breach incident response plan. In the event of a personal data breach that poses a risk to player rights, we will notify the National Privacy Commission (NPC) within 72 hours and affected players without undue delay.

Section 10

Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by a2jl. You may exercise any of these rights by contacting our Data Protection Officer (see Section 15):

a2jl will respond to verifiable data subject requests within thirty (30) calendar days of receipt. Where requests are complex or numerous, a2jl may extend this period by a further thirty (30) days with prior notification.

Section 11

Children's Privacy

The a2jl Platform is strictly intended for adults aged 21 years and older, in accordance with PAGCOR's minimum age requirements for online gaming services in the Philippines. a2jl does not knowingly collect personal data from individuals under the age of 21.

If a2jl becomes aware that personal data has been collected from a person under the age of 21, that individual's Account will be immediately suspended, all funds will be returned to the payment source, any winnings will be forfeited, and all personal data associated with the underage Account will be deleted in accordance with applicable law.

If you are a parent or guardian and believe that a minor has accessed a2jl and provided personal information, please contact our Data Protection Officer immediately at the contact details in Section 15.

Section 12

Marketing Communications

With your consent at the time of registration or through subsequent opt-in, a2jl may send you promotional communications about new games, deposit bonuses, reload offers, seasonal promotions, and VIP loyalty program updates via SMS, email, or in-app notification.

You may opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link included in every marketing email from a2jl;
• Updating your notification preferences in your a2jl Account settings under "Marketing Preferences";
• Contacting a2jl support at [email protected] with a clear opt-out request.

Opting out of marketing communications does not affect delivery of transactional and account-related communications (e.g., deposit confirmations, withdrawal notifications, security alerts, and KYC status updates), which are necessary for the operation of your Account.

a2jl will respect opt-out requests within ten (10) business days of receipt. During that period, you may receive further communications already scheduled prior to the opt-out being processed.

Section 13

Cross-Border Data Transfers

Certain third-party service providers used by a2jl — including game providers, KYC verification platforms, and cloud infrastructure providers — may process personal data outside the Philippines. Where such transfers occur, a2jl ensures that adequate safeguards are in place to protect your data, in compliance with Section 21 of the Data Privacy Act of 2012 and the guidelines of the National Privacy Commission.

Safeguards for cross-border transfers include:

• Contractual clauses in agreements with third-party processors requiring data protection standards equivalent to those required under Philippine law;
• Transfers only to countries or organizations that provide an adequate level of data protection as recognized by the NPC;
• Regular review and audit of cross-border data transfer arrangements.

Section 14

Changes to This Privacy Policy

a2jl reserves the right to update or revise this Privacy Policy from time to time to reflect changes in our data processing practices, the services we offer, or applicable legal and regulatory requirements. All material changes to this Policy will be communicated to registered players via:

• Email notification to the address on file at least fourteen (14) days before the amended Policy takes effect; and
• A prominent notice displayed on the a2jl Platform homepage or login page.

The date of the most recent revision will always be displayed at the top of this page. Your continued use of the a2jl Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised Policy, you should cease using the Platform and may request Account closure.

Section 15

Contact the Data Protection Officer

For all inquiries, requests, or complaints relating to this Privacy Policy or the processing of your personal data by a2jl, please contact our designated Data Protection Officer:

You also have the right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe that a2jl has processed your personal data in violation of the Data Privacy Act of 2012.