jewelph Privacy Policy

1. Who We Are — The Data Controller

jewelph is the operator and data controller responsible for the processing of personal data collected through the jewleph platform at jewelph.org. For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, jewleph is the Personal Information Controller (PIC) with respect to all personal data processed in connection with player accounts, payment transactions, and platform usage.

For all data privacy inquiries, access requests, correction requests, or complaints, please contact jewleph's designated Data Privacy Officer at: [email protected] (plain text, not a clickable link). We are committed to responding to data privacy inquiries within the timeframes mandated by the National Privacy Commission of the Philippines.

2. Personal Data We Collect

jewelph collects the following categories of personal data in connection with the registration, operation, and maintenance of player accounts:

2.1 Registration & Identity Data

• Full legal name as it appears on a valid Philippine government-issued ID
• Date of birth (for age verification — 21+ requirement)
• Registered email address
• Philippine mobile number (Globe, Smart, or DITO)
• Residential address in the Philippines

2.2 KYC & Identity Verification Data

• Copies of valid Philippine government-issued identification documents (e.g., PhilSys National ID, Passport, UMID, Driver's License, SSS/GSIS ID)
• Selfie photographs for facial matching against submitted ID documents
• Proof of address documentation where required for enhanced due diligence

2.3 Financial & Transaction Data

• GCash and Maya account numbers associated with deposits and withdrawals
• Bank account details (BPI, BDO, UnionBank, Metrobank, or other Philippine banks) where InstaPay transfers are used
• Complete records of all deposits, withdrawals, bets placed, game outcomes, and balance movements on the jewleph platform

2.4 Technical & Usage Data

• IP address and approximate geographic location at the time of each login and session
• Device type, operating system, browser type and version
• Session timestamps, pages visited, game sessions accessed, and in-platform navigation patterns
• Cookie identifiers and similar tracking technologies (see Section 6)

2.5 Communications Data

• Records of all communications between you and jewleph customer support, including chat transcripts, email correspondence, and any voice call recordings where applicable
• Responses to surveys, feedback forms, or promotional communications where you have opted to participate

3. How jewelph Uses Your Personal Data

jewleph uses the personal data described in Section 2 for the following specific purposes:

• Account Creation & Management: To register and maintain your jewleph player account, including your PHP wallet, game history, and preference settings.
• Age Verification & KYC Compliance: To verify that you meet the 21+ age requirement mandated by PAGCOR for access to real-money gaming services, and to satisfy anti-money laundering (AML) due diligence requirements under Philippine law.
• Payment Processing: To process deposits from and withdrawals to your registered Philippine payment methods (GCash, Maya, BPI, BDO, etc.), to detect and prevent fraudulent transactions, and to maintain legally required financial records.
• Platform Operation & Game Delivery: To deliver the gaming services you access on the jewleph platform, including live casino games, slots, bingo, and sports betting, and to maintain the technical integrity and security of those services.
• Regulatory Compliance: To comply with jewleph's obligations under PAGCOR's regulatory framework, the Anti-Money Laundering Act (AMLA) of the Philippines, and any other applicable Philippine laws or lawful orders from government authorities.
• Fraud Prevention & Security: To monitor for suspicious activity, unauthorized account access, bonus abuse, collusion, and other conduct prohibited under jewleph's Terms & Conditions, and to take appropriate action where such conduct is detected.
• Customer Support: To investigate and respond to account queries, payment disputes, game complaints, and responsible gaming requests submitted by you through jewleph's support channels.
• Responsible Gaming Obligations: To operate self-exclusion tools, deposit limit controls, and session time management features, and to identify players who may be exhibiting signs of problem gambling behavior warranting intervention.
• Marketing Communications: To send you promotional offers, bonus notifications, VIP program updates, and platform news — but only where you have given your prior consent and subject to your right to opt out at any time.
• Platform Improvement: To analyze aggregated, anonymized usage patterns and technical performance data for the purpose of improving jewleph's platform features, game selection, and user experience.

4. Legal Basis for Processing Under RA 10173

jewelph processes your personal data on the following legal bases as established under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing required to perform our contractual obligations to you under the jewleph Terms & Conditions, including account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with jewleph's obligations under PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine law.
• Legitimate Interests: Processing necessary for fraud prevention, platform security, responsible gaming operations, and internal analytics, where such interests do not override your fundamental privacy rights.
• Consent: Processing for marketing communications and certain optional features, which you may withdraw at any time without affecting your access to the core jewleph platform.

5. Data Sharing & Third-Party Disclosure

5.1 jewleph does not sell your personal data to third parties under any circumstances.

5.2 Service Providers. jewleph shares personal data with carefully selected third-party service providers who process data on our behalf under binding data processing agreements. These include: KYC verification technology providers, payment processing partners (GCash/Maya infrastructure, banking API providers), game software providers (for live casino and RNG game delivery), cloud hosting and data center providers, and fraud detection technology partners. All such providers are required to process your data only as instructed by jewleph and in compliance with applicable Philippine data protection standards.

5.3 Regulatory Authorities. jewleph is required to share player data with PAGCOR and other Philippine government agencies (including the AMLC — Anti-Money Laundering Council) when required by law, regulation, court order, or lawful government request. jewleph will comply with such requirements and, where legally permitted to do so, will notify affected players of material disclosures.

5.4 Business Transfers. In the event of a merger, acquisition, or sale of all or a material part of jewleph's assets, player data may be transferred to the acquiring entity as part of the business transaction, subject to the acquiring entity maintaining equivalent data protection standards and notifying affected players.

6. Cookies & Tracking Technologies

The jewelph platform uses cookies and similar tracking technologies for the following purposes:

• Essential Cookies: Required for platform functionality, including maintaining your login session, loading your account wallet, and remembering your language and game preferences. These cannot be disabled without impairing platform function.
• Security Cookies: Used to detect and prevent fraudulent login attempts, detect multiple account creation, and monitor for suspicious session activity.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players navigate and use the jewleph platform, for the purpose of identifying and resolving performance issues and improving the user experience.
• Marketing Cookies: Used where you have consented to receive tailored promotional content within the jewleph platform based on your game preferences and platform activity. You may withdraw this consent at any time through your account settings.

You may manage your non-essential cookie preferences through the cookie consent banner displayed on your first visit to jewleph.org or at any time via your account settings.

7. Data Retention

jewelph retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account & KYC Data: Retained for a minimum of 5 years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Financial Transaction Records: Retained for a minimum of 10 years as required by AMLA and applicable Philippine tax regulations.
• Game History & Session Logs: Retained for a minimum of 2 years following each session for dispute resolution and regulatory audit purposes.
• Customer Support Communications: Retained for a minimum of 3 years following the closure of each support ticket.
• Marketing Consent Records: Retained for the duration of your account and for 1 year following account closure, as evidence of your consent or opt-out.

Following the expiry of applicable retention periods, jewleph will securely delete or anonymize your personal data using industry-standard data destruction procedures.

8. Data Security Measures

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

• 256-bit TLS encryption for all data transmitted between your device and jewleph's servers
• Encryption at rest for sensitive personal data including KYC documents and financial records
• Multi-factor authentication requirements for internal jewleph staff access to production data systems
• Regular penetration testing and vulnerability assessments by independent security firms
• Role-based access controls limiting staff access to personal data strictly to what is required for their defined job function
• Comprehensive incident response procedures providing for prompt player notification in the event of a data breach affecting your personal information, in accordance with the NPC notification requirements under RA 10173

While jewleph takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are also responsible for maintaining the security of your jewleph account credentials — see Section 3.1 of the Terms & Conditions for your account security obligations.

9. Your Rights Under the Philippine Data Privacy Act (RA 10173)

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jewelph:

• Right to be Informed: The right to know that your personal data is being collected and processed, the purposes of processing, and how it is being used — as set out in this Privacy Policy.
• Right to Access: The right to request a copy of the personal data that jewleph holds about you, including your account profile, KYC submission records, transaction history, and any profiling data used in connection with your account.
• Right to Correction: The right to request correction of any inaccurate, incomplete, or outdated personal data that jewleph holds about you.
• Right to Erasure / Right to be Forgotten: 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 jewleph's regulatory retention obligations described in Section 7.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes at any time. Withdrawal of consent for marketing will not affect your access to the core jewleph gaming platform.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the Philippine National Privacy Commission (NPC) at privacy.gov.ph if you believe that your data privacy rights have been violated by jewleph.

To exercise any of the above rights, please submit your request to the jewleph Data Privacy Officer at [email protected] with your full registered name, your jewleph account ID, and a description of the right you wish to exercise. jewleph will respond to all data rights requests within 15 business days of receipt.

10. Children & Minors — Strict 21+ Policy

The jewelph platform is strictly prohibited to individuals under 21 years of age. jewleph does not knowingly collect personal data from individuals under 21. Age verification is conducted through KYC at account registration, and jewleph will immediately close any account where it is discovered that the registered player is under 21, returning any real-money balance to the payment source where possible and reporting the incident to PAGCOR as required by Philippine gaming regulations.

If you are a parent or guardian and you believe that a minor may have used the jewleph platform, please contact us immediately at [email protected] so that we can take appropriate action without delay.

11. International Data Transfers

jewelph's primary data processing infrastructure is located within the Philippines and in data centers operating under contractual frameworks that comply with Philippine data protection standards. Where it is necessary to transfer your personal data to processors located outside the Philippines (for example, to global game software providers or cloud infrastructure partners), jewleph ensures that such transfers are protected by appropriate safeguards including contractual clauses that provide equivalent data protection to that required under RA 10173, and that receiving parties are bound by jewleph's data processing instructions. jewleph does not transfer personal data to jurisdictions that lack adequate data protection frameworks without implementing such safeguards.

12. Amendments to This Privacy Policy

jewelph may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or platform features. Material changes will be communicated to registered players via email notification or in-platform notice at least 7 days before the revised policy takes effect. The "Last Updated" date at the top of this page will be revised with each update. Your continued use of the jewleph platform following notification of a material policy change constitutes your acknowledgment of the revised Privacy Policy.

13. Contact & Data Privacy Complaints

For any questions, concerns, data access requests, correction requests, or complaints regarding this Privacy Policy or jewleph's data processing practices, please contact our Data Privacy Officer:

• Email: [email protected] (plain text — not a clickable link)
• Response Time: Within 15 business days for formal data rights requests; within 3 business days for general privacy inquiries
• Language: English and Filipino-English accepted

If you are not satisfied with jewleph's handling of your data privacy complaint after contacting us directly, you have the right to escalate your complaint to the Philippine National Privacy Commission (NPC), which is the government authority responsible for enforcing RA 10173 in the Philippines.