ace jl Privacy Policy

1 Introduction

ace jl ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all individuals who access or use the ace jl website, mobile platform, and associated services (collectively, the "Services"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

This Privacy Policy applies to all users of the ace jl platform, including registered players, visitors, and any other persons who interact with our Services. It should be read alongside the ace jl Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

ace jl operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). We take our obligations as a personal information controller seriously and have implemented appropriate technical and organizational measures to safeguard your data.

2 Data Controller Information

For the purposes of the Data Privacy Act of 2012, ace jl acts as the Personal Information Controller in respect of the personal data collected through the ace jl platform. This means ace jl determines the purposes and means of processing your personal information.

If you have any questions, concerns, or requests relating to your personal data, you may contact our Data Privacy Officer (DPO) at:

• Email: [email protected]
• Subject Line: Data Privacy Request – [Your Full Name]
• Response Time: We aim to respond to all data privacy inquiries within five (5) business days.

3 Information We Collect

ace jl collects personal information through various means in the course of providing our Services. The categories of information we collect include:

3.1 Information You Provide Directly

• Registration Data: Full name, date of birth, email address, mobile number, and residential address provided during account creation;
• Identity Verification (KYC) Data: Government-issued Philippine ID documents (e.g., PhilSys National ID, Passport, LTO Driver's License), selfie photographs, and proof of address documents;
• Financial Data: GCash account details, Maya account details, bank account information (BPI, BDO, Metrobank), and transaction history;
• Communications: Records of your interactions with ace jl customer support via live chat, email, or other channels.

3.2 Information Collected Automatically

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers;
• Usage Data: Pages visited, games played, session duration, click patterns, and navigation paths within the ace jl platform;
• Location Data: General geographic location derived from your IP address (country and city level only; precise GPS location is not collected);
• Cookie Data: Information collected through cookies and similar tracking technologies as described in Section 8.

3.3 Information from Third Parties

• Identity verification results from KYC service providers;
• Payment confirmation data from GCash, Maya, and banking partners;
• Fraud detection signals from third-party security and compliance providers.

4 How We Use Your Information

ace jl uses the personal information we collect for the following purposes:

• Account Management: To create, maintain, and manage your ace jl player account;
• Identity Verification: To verify your age (21+) and identity in compliance with regulatory requirements;
• Service Delivery: To process deposits, withdrawals, wagers, and all other transactions on the platform;
• Customer Support: To respond to your inquiries, complaints, and support requests;
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct;
• Regulatory Compliance: To fulfill our obligations under Philippine gaming regulations, anti-money laundering laws, and data protection legislation;
• Platform Improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the ace jl platform;
• Marketing Communications: To send you promotional offers, bonuses, and updates about ace jl — only where you have provided consent or where permitted by applicable law. You may opt out at any time;
• Responsible Gaming: To monitor gaming behavior and provide responsible gaming interventions where appropriate.

5 Legal Basis for Processing

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

• Contractual Necessity: Processing required to perform our contract with you (i.e., to provide the ace jl Services as described in the Terms & Conditions);
• Legal Obligation: Processing required to comply with applicable Philippine laws, including gaming regulations, anti-money laundering requirements, and tax obligations;
• Legitimate Interests: Processing necessary for ace jl's legitimate business interests, including fraud prevention, platform security, and service improvement — where these interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — particularly for marketing communications and non-essential cookies. You may withdraw consent at any time.

6 Sharing Your Information

ace jl does not sell, rent, or trade your personal data. We may share your information with the following categories of recipients only where necessary and lawful:

• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, and other payment service providers, solely to process your deposits and withdrawals;
• KYC & Identity Verification Providers: Third-party identity verification services used to confirm your age and identity in compliance with regulatory requirements;
• Fraud Prevention & Security Partners: Service providers that assist ace jl in detecting and preventing fraudulent activity, money laundering, and other prohibited conduct;
• Technology & Infrastructure Providers: Cloud hosting, data storage, and platform infrastructure providers who process data on our behalf under strict data processing agreements;
• Regulatory & Law Enforcement Authorities: Philippine government agencies, regulators, and law enforcement bodies where disclosure is required by law, court order, or regulatory directive — including PAGCOR and the Anti-Money Laundering Council (AMLC);
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third-party service providers who process personal data on behalf of ace jl are required to do so under written data processing agreements that impose obligations consistent with the Data Privacy Act of 2012 and this Privacy Policy.

7 Data Retention

ace jl retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering regulations;
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later;
• Transaction Records: Retained for a minimum of five (5) years in accordance with financial record-keeping requirements;
• Customer Support Communications: Retained for two (2) years from the date of the last interaction;
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

Where retention beyond these periods is required by law, regulatory directive, or ongoing legal proceedings, ace jl will retain the relevant data until those requirements are satisfied. Upon expiry of the applicable retention period, personal data is securely deleted or anonymized.

8 Cookies & Tracking Technologies

ace jl uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and support security functions. A cookie is a small text file placed on your device when you visit a website.

Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function correctly. These include session authentication cookies and security tokens. They cannot be disabled without affecting core platform functionality;
• Performance & Analytics Cookies: Used to collect anonymized data about how players interact with the ace jl platform, helping us identify areas for improvement;
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience;
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These are only placed with your consent.

Managing Your Cookie Preferences

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the ace jl platform. Instructions for managing cookies are available in the help documentation of your browser.

9 Your Rights Under the DPA

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

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed — which this Privacy Policy fulfills;
• Right of Access: The right to request a copy of the personal data ace jl holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Privacy Officer at [email protected] with the subject line "Data Privacy Request." We will respond within five (5) business days. We may need to verify your identity before processing your request.

10 Data Security

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

• SSL/TLS Encryption: All data transmitted between your device and the ace jl platform is encrypted using industry-standard SSL/TLS protocols;
• Data Encryption at Rest: Sensitive personal and financial data stored on ace jl servers is encrypted at rest using AES-256 encryption;
• Access Controls: Access to personal data is restricted to authorized ace jl personnel on a strict need-to-know basis, enforced through role-based access controls;
• Two-Factor Authentication: Player accounts support two-factor authentication (2FA) to provide an additional layer of security;
• Regular Security Audits: ace jl conducts regular security assessments and penetration testing to identify and remediate vulnerabilities;
• Incident Response: ace jl maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights, we will notify affected players and the NPC in accordance with applicable requirements.

While ace jl takes all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. You are also responsible for maintaining the security of your account credentials as described in the Terms & Conditions.

11 Children's Privacy

The ace jl platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. ace jl does not knowingly collect personal data from individuals under the age of 21.

If ace jl becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the ace jl platform, please contact us immediately at [email protected].

12 International Data Transfers

In the course of providing our Services, your personal data may be transferred to and processed in countries other than the Philippines — for example, where our technology infrastructure providers or KYC partners operate servers in other jurisdictions.

Where such transfers occur, ace jl ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012. These safeguards may include contractual clauses that impose data protection obligations on the recipient, or transfers to jurisdictions that have been assessed as providing an adequate level of data protection.

By using the ace jl platform, you acknowledge and consent to the transfer of your personal data to other countries as described in this section, subject to the protections outlined above.

13 Changes to This Policy

ace jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email or an in-platform notification, and the updated policy will be posted on this page with a revised "Last Updated" date.

Your continued use of the ace jl platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed of how we protect your personal data.

14 Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or the way ace jl handles your personal data, please contact our Data Privacy Officer:

• Email: [email protected]
• Subject Line: Privacy Policy Inquiry – [Your Full Name]
• Live Chat: Available 24/7 via the ace jl platform
• Response Time: We aim to respond to all privacy-related inquiries within five (5) business days.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.