jjmmm Privacy Policy — How We Handle Your Personal Data

1Overview and Who This Policy Covers

jjmmm operates as an online gaming platform serving eligible Filipino adults. As part of running the platform, jjmmm collects and processes personal information from registered account holders, persons who have started but not completed the registration process, and visitors who interact with the jjmmm website.

This Privacy Policy applies to all data collected and processed by jjmmm in connection with the platform, including information gathered through the website, any mobile-optimised interface, customer support communications, and payment processing. It does not apply to third-party websites or services that may be linked from jjmmm, even where jjmmm has a business relationship with those services.

jjmmm is committed to processing personal data in a manner consistent with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and the rules and regulations issued by the National Privacy Commission of the Philippines. Where those obligations require specific action on the part of jjmmm, those actions are described throughout this document.

2Personal Data We Collect from Filipino Players

jjmmm collects the minimum personal information necessary to provide the platform, comply with legal obligations, and protect the safety of all players. The categories of data collected include:

jjmmm does not collect or store full payment card numbers. Payment card transactions are processed by a certified payment service provider, and jjmmm retains only the information needed to reconcile transactions and handle disputes.

3How jjmmm Collects Your Information

Personal data reaches jjmmm through several channels:

• Direct input: Information you type into the registration form, verification documents you upload, payment details you submit, and messages you send to jjmmm support.
• Automated collection: Technical data gathered automatically when you visit or interact with jjmmm, including cookies, server logs, and session-tracking tools. See Section 9 for more detail on cookies.
• Third-party sources: Identity verification providers and payment processors may share data with jjmmm as part of account verification or transaction processing, strictly for the purpose of completing those activities.
• Responsible gaming systems: Where jjmmm participates in shared exclusion databases or verification registries, relevant data may be received from those systems to prevent ineligible persons from accessing the platform.

4Why jjmmm Uses Your Personal Data

jjmmm uses the personal information it collects for specific, legitimate purposes. We do not process your data in ways that are incompatible with the reason it was collected. The primary purposes are:

• Account creation and management: Setting up, verifying, and maintaining your jjmmm player account, including identity checks required by law.
• Payment processing: Processing deposits and withdrawals in PHP, reconciling transactions, and handling payment disputes.
• Platform operation: Delivering the games, sports betting markets, promotions, and other features available on jjmmm.
• Legal and regulatory compliance: Meeting obligations under Philippine gaming regulations, anti-money laundering requirements, and data privacy law.
• Responsible gaming: Monitoring account activity for patterns associated with problem gambling, applying player-set limits, and maintaining exclusion records.
• Security and fraud prevention: Detecting and preventing unauthorised account access, duplicate account creation, payment fraud, and bonus abuse.
• Customer support: Responding to account queries, resolving complaints, and providing technical assistance to jjmmm players.
• Platform improvement: Analysing aggregated, anonymised usage patterns to improve the jjmmm player experience over time.
• Marketing communications: Sending promotions and platform updates to players who have opted into marketing communications, where permitted by law.

jjmmm will never use your personal data to make fully automated decisions that produce significant legal or similarly consequential effects on your account without providing an avenue for human review upon request.

5Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 and its implementing rules, jjmmm processes personal data on the following legal grounds depending on the activity involved:

• Consent: For marketing communications and for processing data categories where consent is required by law. You may withdraw consent at any time without affecting the lawfulness of processing that occurred before withdrawal.
• Contractual necessity: For data processing required to create your account, operate your jjmmm account, and complete deposit and withdrawal transactions.
• Legal obligation: For identity verification, anti-money laundering checks, responsible gaming record-keeping, and any other processing mandated by applicable Philippine law or the relevant gaming regulatory authority.
• Legitimate interests: For fraud prevention, platform security, and aggregated analytics used to improve the jjmmm player experience, where those interests are not overridden by your data protection rights.

6Sharing Your Data with Third Parties

jjmmm does not sell your personal data. We do not share your information with third parties for their own marketing purposes. Data is shared with third parties only in the following circumstances and to the minimum extent necessary:

• Payment processors: To facilitate deposits and withdrawals using GCash, Maya, GrabPay, Coins.ph, InstaPay, PESONet, and card networks. These processors handle transactions under their own privacy and security frameworks and are not permitted to use your data beyond transaction processing.
• Identity verification providers: To confirm your age and identity during account registration or when enhanced verification is required. These providers receive only the information needed for the specific check.
• Responsible gaming registries: Where jjmmm participates in a shared exclusion database, relevant information may be shared with or received from that registry to prevent access by excluded persons.
• Regulatory and law enforcement authorities: Where jjmmm is required by law, court order, or valid regulatory demand to disclose player information. jjmmm will make reasonable efforts to notify affected players where legally permitted to do so.
• Technology and hosting providers: Service providers that support jjmmm's technical infrastructure process data on jjmmm's behalf under strict data processing agreements and are not permitted to use that data for any other purpose.

All third parties that receive jjmmm player data are contractually required to maintain appropriate security standards and to process that data only for the purpose for which it was shared.

7How Long jjmmm Keeps Your Data

jjmmm retains personal data for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law, whichever is longer. Specific retention periods include:

• Account registration and identity verification data is retained for a minimum period required by Philippine gaming regulations and anti-money laundering law, typically five years from account closure.
• Transaction records including deposits, withdrawals, bets, and game outcomes are retained for the period required for regulatory reporting, currently a minimum of five years.
• Responsible gaming records including limit settings, cool-off periods, and self-exclusion history are retained for the duration of any exclusion period plus the mandatory review period that follows.
• Marketing preference data is retained until you withdraw consent or until the communication relationship ends, whichever comes first.
• Support communications are retained for a reasonable period sufficient to resolve any related dispute or regulatory inquiry, typically three years from the date of the interaction.

When personal data is no longer required, jjmmm destroys or anonymises it in a secure manner. Anonymised data that cannot be traced back to an individual may be retained indefinitely for analytical purposes.

8Security of Your Personal Data

jjmmm implements technical and organisational security measures appropriate to the risk level associated with the personal data we process. These measures include:

• Encryption of personal data in transit using industry-standard TLS protocols.
• Encryption of stored sensitive data including identity records and financial information.
• Access controls that limit which jjmmm team members and systems can view personal player data, based on the principle of least privilege.
• Regular security assessments of jjmmm systems and third-party integrations.
• Secure procedures for handling data breaches, including notification to the National Privacy Commission and affected players where required by the Data Privacy Act.

While jjmmm maintains robust security practices, no online platform can guarantee absolute security against all possible threats. Players contribute to their own account security by maintaining a strong, unique password, not sharing login credentials, and logging out fully after each session. If you suspect unauthorised access to your jjmmm account, contact us immediately at support@jjmmm.app.

9Cookies and Tracking Technologies

jjmmm uses cookies and similar tracking technologies on the platform. A cookie is a small text file stored on your device by your browser. jjmmm uses the following categories of cookies:

• Essential cookies: Required for the platform to function, including maintaining your logged-in session and storing your game preferences. These cannot be disabled without affecting platform operation.
• Analytics cookies: Used to understand how players interact with jjmmm in aggregate — for example, which pages are visited most, how long sessions last, and where players encounter difficulties. This data is anonymised before analysis.
• Functional cookies: Store preferences such as language settings and responsible gaming reminder choices to improve your experience across jjmmm sessions.
• Marketing cookies: Where you have consented to receive marketing communications, these cookies help jjmmm understand whether those communications were relevant and how they were engaged with.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using jjmmm, though some functional preferences may not be retained between sessions. Disabling essential cookies will affect the ability to log in and use the platform.

10Your Data Rights as a jjmmm Player

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