Privacy Policy
for ffjl Casino

ffjl ("ffjl," "we," "us," or "our") operates the online gaming platform accessible at ffjl.app. For the purposes of this Privacy Policy, ffjl acts as the data controller responsible for the personal data of players and visitors who access the ffjl platform.

This Privacy Policy applies to all personal data collected through the ffjl website, mobile-optimized platform, customer support channels, and any other service operated under the ffjl brand. It applies to all users located in the Philippines and to any other jurisdiction where ffjl's services are lawfully accessed.

ffjl collects personal data in several categories depending on how you interact with the platform. The table below summarizes the types of data we collect and the context in which each type is gathered.

ffjl does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where such information is voluntarily provided by a player in the context of a responsible gaming self-assessment or support request.

ffjl collects personal data through the following methods:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or updating your account profile.
• Automated technologies: Technical data collected automatically when you access the ffjl platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 07 for full details on cookies.
• Third-party sources: Identity and fraud-check data received from KYC verification service providers, payment processors (such as GCash and PayMaya), and fraud prevention partners, where permitted by applicable law.
• Publicly available sources: In limited circumstances, ffjl may verify information against publicly available records as part of its AML compliance obligations.

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

• Account registration and management: To create and maintain your ffjl player account, verify your identity, and manage your account settings and preferences.
• Age and identity verification (KYC): To confirm that you meet the minimum age requirement of 21 years for participation in casino-style gaming in the Philippines, and to verify your identity as required by applicable regulations.
• Transaction processing: To process deposits, withdrawals, and bonus credits to and from your ffjl account via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Legal and regulatory compliance: To comply with Anti-Money Laundering (AML) obligations, PAGCOR-related regulatory requirements, tax reporting obligations, and any other applicable Philippine law or regulatory directive.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, and other security threats to the ffjl platform and its players.
• Customer support: To respond to your queries, complaints, and support requests, and to maintain records of communications for quality assurance and dispute resolution purposes.
• Responsible gaming: To monitor gaming patterns that may indicate problem gambling behavior, to apply responsible gaming tools at your request, and to fulfill ffjl's duty of care obligations to players.
• Marketing and promotions: To send you promotional offers, bonus notifications, and platform updates where you have opted in to receive such communications. You may opt out at any time through your account settings.
• Platform improvement: To analyze usage patterns, conduct research, and improve the ffjl platform's features, performance, and user experience.
• Personalization: To tailor the ffjl gaming experience to your preferences, including game recommendations and relevant promotional offers.

Under the Data Privacy Act of 2012 and its implementing rules, ffjl processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and ffjl — including account creation, game access, and financial transactions — is necessary for the delivery of ffjl's services.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and any directives from PAGCOR or other competent regulatory authorities.
• Legitimate interests: Processing carried out for ffjl's legitimate business interests, including fraud prevention, platform security, and improving the quality of ffjl's services, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and optional personalization features. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

ffjl does not sell your personal data. We may share your data with the following categories of recipients only where necessary and in accordance with applicable law:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals to and from your ffjl account.
• KYC and identity verification providers: Third-party service providers that assist ffjl in verifying player identities and ages as required by applicable regulations.
• Fraud prevention and AML partners: Service providers that assist ffjl in detecting and preventing fraudulent activity and complying with Anti-Money Laundering obligations.
• Technology and infrastructure providers: Cloud hosting, data storage, and platform technology providers that process data on ffjl's behalf under strict data processing agreements.
• Game content providers: Third-party game studios and live dealer operators whose games are available on the ffjl platform, to the extent necessary for game delivery and integrity monitoring.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where disclosure is required by law, court order, or regulatory directive.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by ffjl, subject to professional confidentiality obligations.

All third-party service providers that process personal data on ffjl's behalf are required to do so only on ffjl's documented instructions and in compliance with applicable data protection law. ffjl does not authorize any third party to use your personal data for their own independent purposes.

ffjl uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and deliver a personalized experience. The following types of cookies are used on the ffjl platform:

Strictly necessary cookies cannot be disabled as they are essential for the platform to function. You may manage your preferences for functional, analytics, and marketing cookies through your browser settings or the ffjl cookie preference center. Note that disabling certain cookies may affect the functionality of the ffjl platform.

ffjl does not use third-party advertising cookies to track your activity across other websites for the purpose of serving you targeted advertisements on external platforms.

ffjl 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. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account relationship with ffjl, and for a minimum of five (5) years following account closure, as required by AML regulations and applicable Philippine law.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AML and tax record-keeping obligations.
• Gaming history: Retained for the duration of your account and for up to three (3) years following account closure, for dispute resolution and regulatory compliance purposes.
• Customer support communications: Retained for up to three (3) years from the date of the last communication, for quality assurance and dispute resolution purposes.
• Marketing data: Retained until you withdraw your marketing consent, after which it will be deleted or anonymized within a reasonable timeframe.
• Technical and log data: Retained for up to twelve (12) months for security monitoring and platform performance analysis.

When personal data is no longer required for any lawful purpose, ffjl will securely delete or anonymize it in accordance with its data disposal procedures. Anonymized data that can no longer be linked to an individual may be retained indefinitely for statistical and research purposes.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ffjl. You may exercise any of these rights by contacting ffjl's support team using the contact details in Section 14.

ffjl will respond to all valid data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case ffjl will notify you of the extension and the reason for it.

If you are not satisfied with ffjl's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

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

• Encryption: All data transmitted between your device and the ffjl platform is encrypted using TLS (Transport Layer Security). Sensitive data stored on ffjl's servers is encrypted at rest.
• Access controls: Access to personal data within ffjl's systems is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-factor authentication: ffjl offers two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Regular security assessments: ffjl conducts regular security reviews, vulnerability assessments, and penetration testing to identify and address potential security weaknesses.
• Incident response: ffjl maintains a data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, ffjl will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act.

While ffjl takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You also play an important role in keeping your data safe — please use a strong, unique password for your ffjl account and enable two-factor authentication.

The ffjl platform is strictly intended for adults aged 21 years and above. ffjl does not knowingly collect personal data from individuals under the age of 21. The minimum age for participation in casino-style gambling in the Philippines is 21 years, and ffjl enforces this requirement through its registration and KYC verification processes.

If you are a parent or guardian and believe that your child has registered on the ffjl platform, please contact ffjl support immediately so that the account can be investigated and closed without delay.

The ffjl platform may contain links to third-party websites or services — for example, payment provider portals or game content providers. This Privacy Policy applies only to the ffjl platform and does not cover the data practices of any third-party websites or services.

ffjl is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party services you access through or in connection with the ffjl platform before providing any personal data to those services.

ffjl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The most current version of this Privacy Policy will always be available on this page, with the effective date updated accordingly.

For material changes to this Privacy Policy, ffjl will provide advance notice to registered players via the email address associated with their account, or through a prominent notice on the platform. We encourage you to review this Privacy Policy periodically to stay informed about how ffjl protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or ffjl's handling of your personal data, please contact the ffjl support team through the following channels:

• Live Chat: Available 24/7 directly on the ffjl platform. This is the fastest way to reach our team for urgent data privacy matters.
• Email: [email protected] — please include "Data Privacy" in your message subject so your inquiry is directed to the appropriate team.

ffjl aims to respond to all data privacy inquiries within twenty-four (24) hours. For formal data rights requests, ffjl will respond within thirty (30) days as outlined in Section 09.

If you are not satisfied with ffjl's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.