smjljl Privacy Policy

Welcome to the smjljl Privacy Policy. smjljl ("we", "us", "our") is the operator of the online gaming platform accessible at https://smjljl.net (the "Platform"). We are fully committed to protecting the privacy, security, and personal data of every player who registers, accesses, or uses the smjljl Platform — whether you are gaming from Manila, Cebu, Davao, Quezon City, Makati, or anywhere else across the Philippines.

This Privacy Policy explains what personal data smjljl collects from you, why we collect it, how we use and protect it, with whom we share it, and what rights you hold under applicable Philippine law. This Policy forms part of the smjljl Terms and Conditions and should be read together with that document.

smjljl processes personal data in compliance with the Republic of the Philippines Data Privacy Act of 2012 (Republic Act No. 10173, or "DPA") and all implementing rules and regulations issued by the National Privacy Commission (NPC). We take our obligations under Philippine data privacy law seriously, and we have put robust technical and organisational measures in place to safeguard your information at every stage of processing.

smjljl is the data controller responsible for your personal information collected via the smjljl Platform. As data controller, smjljl determines the purposes for which and the manner in which your personal data is processed. smjljl operates in compliance with applicable Philippine gaming regulations and adheres to PAGCOR responsible gaming guidelines.

For all data privacy inquiries, requests, and complaints, you may contact smjljl's Data Protection Officer (DPO) at the contact details provided in Section 15 of this Policy. Our DPO is responsible for overseeing data protection strategy and ensuring compliance with RA 10173 on a day-to-day basis.

smjljl collects several categories of personal data in the course of providing the Platform and its services. The table below summarises the key categories and examples of the data we collect:

smjljl collects your personal data through several channels and methods, all of which are designed to be transparent and proportionate to our legitimate purposes:

1. Direct Registration: When you create a smjljl account, you voluntarily provide identity, contact, and financial information through the registration form.
2. KYC Verification: When smjljl requests identity verification, you submit copies of government-issued documents and supporting materials.
3. Deposits and Withdrawals: Payment transactions through GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency channels generate financial data records associated with your account.
4. Gaming Activity: Your in-platform behaviour — games played, wagers placed, outcomes, session times — is recorded automatically by smjljl's gaming systems.
5. Cookies and Tracking Technologies: smjljl uses cookies and similar technologies to collect technical and usage data automatically when you access the Platform. See Section 10 for full details.
6. Customer Support: When you contact smjljl's support team via live chat or email, the content and metadata of those communications is recorded and retained.
7. Third-Party Sources: smjljl may receive data about you from third-party identity verification providers, payment processors, fraud detection services, and publicly available databases for the purpose of KYC and AML compliance.

smjljl uses the personal data we collect solely for the purposes described below. We do not use your data for any purpose that is incompatible with the reason it was originally collected without first obtaining your consent:

• Account Management: To create, maintain, and administer your smjljl account, including processing deposits, withdrawals, and bonus credits.
• Identity Verification (KYC): To verify your identity, age (21+), and eligibility as required by PAGCOR regulations and Philippine anti-money laundering law.
• Service Delivery: To provide access to smjljl's full suite of games including slots, bingo, God Fish Slicing, Mines Gold, live casino, and sports betting features.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, money laundering, collusion, and other prohibited conduct on the Platform.
• Regulatory Compliance: To fulfil obligations under Philippine law, PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and RA 10173.
• Customer Support: To respond to your queries, resolve account issues, and improve our support processes.
• Responsible Gaming: To monitor gaming behaviour and apply responsible gaming tools including deposit limits, loss limits, and self-exclusion where appropriate.
• Platform Improvement: To analyse usage patterns, conduct internal research, and improve the features, performance, and security of the smjljl Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and updates — but only where you have provided explicit consent. You may withdraw consent at any time.
• Legal Proceedings: To establish, exercise, or defend legal claims in the event of disputes or regulatory investigations.

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

1. Contractual Necessity: Processing your identity, contact, and financial data is necessary for smjljl to perform its contractual obligations to you under the smjljl Terms and Conditions — including account creation, payment processing, and service delivery.
2. Legal Obligation: smjljl is required by Philippine law — including PAGCOR regulations, the AMLA, and RA 10173 — to collect and process certain categories of data (particularly for KYC and AML compliance).
3. Legitimate Interests: smjljl processes technical and usage data on the basis of its legitimate interests in maintaining platform security, preventing fraud, and improving its services, provided that these interests are not overridden by your fundamental rights and freedoms.
4. Consent: For marketing communications and any processing of sensitive personal information, smjljl relies on your explicit, freely given, and informed consent. You may withdraw consent at any time by contacting [email protected].

smjljl does not sell, rent, or trade your personal data to any third party for their own marketing purposes. We share your data only in the following limited and controlled circumstances:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency payment gateways receive financial transaction data necessary to process your deposits and withdrawals.
• KYC and Identity Verification Providers: Licensed third-party KYC providers receive copies of your identity documents to perform age and identity checks as required by regulation.
• Game Providers: Third-party game studios and live dealer providers may receive anonymised or pseudonymised gaming session data necessary to deliver their games via the smjljl Platform.
• Fraud Prevention Services: Specialist fraud detection and anti-money laundering service providers receive relevant transaction and behavioural data to assist smjljl in identifying and preventing illicit activity.
• Regulatory Authorities: smjljl will disclose personal data to PAGCOR, the AMLC (Anti-Money Laundering Council), the National Privacy Commission, and other competent Philippine authorities when required by law or regulation.
• Law Enforcement: smjljl will cooperate with law enforcement agencies and disclose data where required by a valid court order, subpoena, or other lawful process.
• Professional Advisers: Lawyers, auditors, and other professional advisers bound by confidentiality obligations may receive personal data in the course of providing services to smjljl.

smjljl retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following general retention periods apply:

After the applicable retention period has elapsed, smjljl will securely delete or anonymise your personal data in accordance with our internal data disposal procedures. Where data cannot be immediately deleted due to technical constraints, it will be isolated and protected until deletion is possible.

smjljl implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security framework includes:

• 256-Bit SSL Encryption: All data transmitted between your device and the smjljl Platform is protected by bank-grade SSL/TLS encryption.
• Encryption at Rest: Sensitive personal data stored on smjljl servers — including identity documents and financial records — is encrypted at rest using industry-standard algorithms.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. smjljl staff undergo regular data privacy training and are bound by confidentiality obligations.
• Two-Factor Authentication: smjljl offers two-factor authentication (2FA) on player accounts to reduce the risk of unauthorised access.
• Regular Security Audits: smjljl conducts periodic security assessments, penetration testing, and vulnerability scans to identify and address potential weaknesses.
• Incident Response: smjljl maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights, smjljl will notify the National Privacy Commission and affected players within the timeframes required under RA 10173.

smjljl uses cookies and similar technologies — including web beacons, pixel tags, and local storage — to enhance your experience on the Platform, maintain session integrity, and collect usage analytics. The following types of cookies are used:

1. Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as login sessions, account security, and game loading. These cookies cannot be disabled without impairing Platform functionality.
2. Performance and Analytics Cookies: These cookies collect anonymised information about how players use the Platform — pages visited, features used, and errors encountered — to help smjljl improve the product. This data is aggregated and does not identify individual users.
3. Functional Cookies: These cookies remember your preferences (such as language settings and game view preferences) to personalise your experience on return visits.
4. Targeting and Marketing Cookies: With your consent, smjljl may use targeting cookies to deliver relevant promotional content and measure the effectiveness of marketing campaigns. You may opt out of marketing cookies at any time through your browser settings or by contacting our support team.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the smjljl Platform. For more information on managing cookies in your browser, refer to your browser's help documentation.

Under the Philippine Data Privacy Act of 2012 and the implementing rules of the National Privacy Commission, you have the following rights in respect of your personal data held by smjljl:

To exercise any of these rights, please contact smjljl's Data Protection Officer at [email protected] with the subject line "Data Privacy Request". smjljl will respond to all verified requests within fifteen (15) business days in accordance with NPC guidelines. We may require you to verify your identity before processing your request.

smjljl is strictly a 21+ platform. We do not knowingly collect personal data from any person under the age of twenty-one (21). Real-money online gambling is prohibited for persons under 21 under Philippine law and PAGCOR regulations, and smjljl enforces this requirement without exception through our KYC verification process.

If smjljl becomes aware that personal data has been collected from a person under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that smjljl may have inadvertently collected data from a minor, please contact us immediately at [email protected].

smjljl primarily processes your personal data within the Philippines. However, some of our third-party service providers — including game providers, identity verification partners, and cloud infrastructure providers — may process data in other jurisdictions. Where such transfers occur, smjljl ensures that adequate safeguards are in place to protect your personal data to at least the same standard as required under Philippine law.

smjljl implements appropriate contractual protections with all international data processors, including standard data processing agreements that require recipients to adhere to data protection standards consistent with RA 10173. smjljl will not transfer your personal data to jurisdictions that do not offer an adequate level of data protection without first implementing appropriate safeguards and, where required, notifying the National Privacy Commission.

smjljl reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, smjljl will notify registered players via email to their registered address and/or by displaying a prominent notice on the Platform for a reasonable period before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically to stay informed about how smjljl protects your personal data. Your continued use of the smjljl Platform after the effective date of any changes constitutes your acceptance of the revised Policy.

For all data privacy-related queries, requests, or complaints — including requests to exercise your rights under RA 10173 — please contact smjljl's Data Protection Officer. Our DPO is available to assist Filipino players across all areas of the Philippines and will respond to all data privacy requests within the timeframes prescribed by the National Privacy Commission.

If you are not satisfied with smjljl's response to your data privacy request, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at https://www.privacy.gov.ph. smjljl cooperates fully with all NPC investigations and inquiries.