Privacy Policy — wjl2

// 01 Introduction

This Privacy Policy ("Policy") is issued by wjl2 ("wjl2", "we", "us", "our") and applies to all personal data collected through the wjl2 online gaming platform accessible at wjl2.net, including any mobile-optimised web application, customer support channels, and any other wjl2-operated digital service. This Policy explains the types of personal data we collect from players and visitors, the purposes for which we process that data, the circumstances in which we may share it with third parties, and the rights available to you under applicable Philippine law.

wjl2 is fully committed to complying with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), and the Implementing Rules and Regulations ("IRR") issued by the National Privacy Commission ("NPC"). We are equally committed to meeting any data-related requirements imposed by PAGCOR under wjl2's gaming licence.

// 02 Data Controller Identity

For the purposes of the Data Privacy Act of 2012, wjl2 is the personal information controller in respect of all personal data collected through the wjl2 platform. wjl2 operates under a valid PAGCOR online gaming licence and is subject to PAGCOR's data governance requirements in addition to those imposed by the NPC.

wjl2 has appointed a Data Protection Officer ("DPO") in accordance with Section 21 of the DPA and the NPC's registration requirements. The DPO is responsible for ensuring ongoing compliance with the DPA and acting as the primary point of contact for data-related enquiries and complaints. Contact details for the DPO are provided in Section 13 of this Policy.

// 03 Categories of Personal Data Collected

wjl2 collects personal data falling into the following categories. The full breakdown of data types, purposes, and legal bases is available in the Data Inventory table above. In summary, the categories are:

• Identity Data — information that identifies you as an individual, including your full legal name, date of birth, nationality, and copies of government-issued identification documents (e.g., PhilSys National ID, Philippine passport, SSS UMID, or driver's licence);
• Contact Data — your registered email address, Philippine mobile number, and current residential address;
• Financial Data — details of the payment methods linked to your account, including GCash account information, PayMaya account details, and bank account holder names for BPI, BDO, and Metrobank transactions;
• Transaction Data — a full record of all deposits, withdrawals, bonuses claimed, bets placed, and game results associated with your wjl2 account;
• Technical Data — your IP address, device identifiers, browser type and version, operating system, and session activity logs;
• Usage Data — information about how you navigate and interact with the wjl2 platform, including which games you play and how frequently;
• Communications Data — the content of any communications you send to wjl2 through live chat, email, or support tickets;
• Marketing Preferences — your opted-in or opted-out status for promotional communications.

wjl2 does not knowingly collect sensitive personal information as defined under Section 3(l) of the DPA (such as health data, religious beliefs, or political affiliations) unless directly required to do so by a specific legal obligation.

// 04 How We Collect Your Personal Data

wjl2 collects personal data through the following channels and methods:

• Direct collection at registration — when you create your wjl2 account, you actively provide your name, date of birth, contact details, and initial payment information;
• KYC document submission — when you submit identity documents and proof of address through the account verification portal;
• Platform interactions — data generated automatically as you place bets, play games, make deposits, and request withdrawals;
• Customer support interactions — data provided when you contact wjl2 via live chat or email, including the content of those communications;
• Automated technical collection — data collected passively via cookies, session tracking, and server logs when you access the wjl2 website;
• Third-party verification services — identity verification data returned by licensed KYC providers engaged by wjl2 to authenticate documents submitted by players;
• Payment processors — transaction confirmation data returned by GCash, PayMaya, BPI, BDO, and Metrobank upon processing a deposit or withdrawal.

// 05 How wjl2 Uses Your Personal Data

wjl2 processes your personal data for the following specific purposes, each of which is supported by an identified legal basis under Section 12 or Section 13 of the DPA:

• Account creation and management — to register your account, authenticate your identity at login, and manage your account settings throughout your relationship with wjl2 (legal basis: contractual necessity);
• Age and identity verification — to confirm that you meet the minimum age requirement of 21 years old in compliance with PAGCOR regulations (legal basis: legal obligation);
• Payment processing — to process deposits and withdrawals using your nominated payment methods and to reconcile transaction records (legal basis: contractual necessity);
• Anti-money laundering compliance — to meet the reporting and monitoring obligations imposed by the Anti-Money Laundering Act (Republic Act No. 9160, as amended) and AMLC regulations (legal basis: legal obligation);
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, account sharing, and other prohibited conduct (legal basis: legitimate interest);
• Customer support — to respond to your enquiries, process complaints, and maintain records of support interactions for quality assurance purposes (legal basis: contractual necessity / legitimate interest);
• Responsible gaming — to monitor your gaming behaviour for signs of problem gambling, enforce self-exclusion requests, and apply deposit limits or cooling-off periods (legal basis: legal obligation / legitimate interest);
• Regulatory reporting — to provide transaction records, player data, and activity reports to PAGCOR, AMLC, or other Philippine regulatory authorities as required by law (legal basis: legal obligation);
• Platform improvement — to analyse usage patterns and technical performance data to improve the wjl2 platform experience (legal basis: legitimate interest);
• Marketing communications — to send you promotional offers, bonus notifications, and platform updates, but only where you have given your explicit consent to receive such communications (legal basis: consent).

// 06 Data Sharing & Third-Party Disclosure

wjl2 does not sell, rent, or trade your personal data to third-party advertisers or data brokers. We share personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• PAGCOR and Philippine regulatory authorities — wjl2 is required to share player data, transaction records, and activity reports with PAGCOR under its gaming licence conditions, and with the AMLC under Anti-Money Laundering Act obligations;
• Licensed KYC and identity verification providers — to process and verify identity documents submitted during account registration and the KYC process. These providers are contractually bound to process data solely for verification purposes;
• Payment processing partners — GCash, PayMaya, BPI, BDO, and Metrobank receive the transaction data necessary to process your deposits and withdrawals. These partners operate under their own data privacy frameworks and are regulated by the Bangko Sentral ng Pilipinas (BSP);
• IT infrastructure and cloud service providers — wjl2 uses third-party cloud hosting and technical infrastructure providers to operate the platform. These providers act as personal information processors under written agreements that impose equivalent data protection obligations;
• Customer support platform providers — our live chat and ticketing system provider processes communication data on our behalf under a processor agreement;
• Law enforcement and courts — wjl2 may disclose personal data to Philippine law enforcement agencies or courts where required by a lawful order, subpoena, or other legal process;
• Professional advisors — lawyers, auditors, and accountants engaged by wjl2 may access personal data on a strictly confidential basis in connection with their professional services.

Where wjl2 engages third-party processors, we ensure that appropriate data processing agreements are in place that require those processors to maintain security standards equivalent to those applied by wjl2, and to process data only on wjl2's documented instructions.

// 07 Data Retention

wjl2 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by Philippine law or PAGCOR licensing conditions. The following general retention guidelines apply:

• Account and identity data — retained for the duration of your active account relationship with wjl2, plus a minimum of five (5) years following account closure, in compliance with AMLC record-keeping requirements under the Anti-Money Laundering Act;
• Transaction and financial records — retained for a minimum of five (5) years from the date of the transaction, consistent with AMLC and PAGCOR requirements;
• KYC documents — retained for a minimum of five (5) years from the date of verification, or longer if required by a specific regulatory instruction;
• Customer support communications — retained for two (2) years from the date of the last support interaction, unless the content is relevant to an ongoing dispute, in which case retention continues until the dispute is fully resolved;
• Technical and usage data (server logs) — retained for up to twelve (12) months for security monitoring purposes, after which logs are anonymised or deleted;
• Marketing preference data — retained until you withdraw your consent, after which your details are removed from active marketing lists within thirty (30) days.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised so that it can no longer be attributed to an identified individual. Where full deletion is not immediately possible due to backup architecture, data in backup systems is overwritten in the normal course of the backup rotation cycle.

// 08 Data Security Measures

wjl2 implements a layered security framework to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include, but are not limited to:

• Encryption in transit — all data transmitted between your browser or device and the wjl2 platform is encrypted using TLS 1.2 or higher. Our SSL certificate is maintained by a recognised certificate authority;
• Encryption at rest — sensitive personal data stored in wjl2 databases is encrypted using AES-256 encryption;
• Access controls — access to personal data within wjl2's internal systems is restricted to authorised personnel on a strict need-to-know basis. Access rights are reviewed regularly and revoked upon change of role or employment;
• Multi-factor authentication — internal wjl2 systems handling personal data require multi-factor authentication for all staff access;
• Penetration testing — the wjl2 platform undergoes periodic security penetration testing conducted by independent cybersecurity professionals;
• Incident response procedures — wjl2 maintains a documented data breach response plan. In the event of a personal data breach that is likely to result in harm to affected players, wjl2 will notify the NPC within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay as required by the DPA and NPC Circular 16-03.

While wjl2 takes all reasonable technical and organisational steps to protect your data, no digital transmission or storage system is completely immune to security risks. You also play a role in protecting your data by keeping your account credentials confidential and reporting any suspected unauthorised access to wjl2 support immediately.

// 09 Your Data Rights Under RA 10173

Under the Data Privacy Act of 2012 and the NPC's implementing regulations, you — as a data subject — have the following rights in relation to your personal data held by wjl2. These rights are genuine and enforceable, and wjl2 is committed to honouring each of them:

To exercise any of the above rights, submit a written request to wjl2's Data Protection Officer using the contact details provided in Section 13. We will respond to all verified data rights requests within thirty (30) calendar days of receipt. In cases of complex or high-volume requests, we may extend this period by a further thirty (30) days, with prior notice to you.

Please note that certain rights — particularly erasure — may be limited where wjl2 is legally required to retain specific data. For example, transaction records subject to AMLC retention requirements cannot be deleted on request during the mandatory retention period.

// 10 Cookies & Tracking Technologies

The wjl2 platform uses cookies and similar tracking technologies to provide essential platform functionality, improve user experience, and gather aggregate usage analytics. Cookies are small text files stored on your device when you visit the wjl2 website. The types of cookies we use are as follows:

• Strictly necessary cookies — required for the platform to function correctly. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery (CSRF). These cookies cannot be disabled without preventing the platform from operating;
• Functional cookies — remember your preferences, such as your chosen language or game lobby view settings ;
• Analytics cookies — collect aggregate, anonymised data about how players navigate the wjl2 platform. This data helps us identify performance issues and improve the overall player experience. We do not use analytics cookies to build individual profiles;
• Security cookies — used to detect and prevent fraudulent login attempts, bot activity, and other malicious behaviour on the platform.

You may manage your cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling strictly necessary cookies will impair the functionality of the wjl2 platform and may prevent you from accessing your account. Analytics and functional cookies can be disabled without affecting core platform access.

wjl2 does not use third-party advertising cookies or cross-site tracking technologies that profile you across different websites for commercial advertising purposes.

// 11 Minors & Age Policy

The wjl2 platform is strictly intended for adults aged 21 years old and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. wjl2 does not knowingly collect personal data from individuals under the age of 21.

If you are a parent or guardian and believe that a minor in your care has registered an account with wjl2, please contact our support team immediately at [email protected]. We will investigate and take appropriate action within 48 hours of a verified report.

Age verification is a mandatory step in the wjl2 KYC process. No account may be fully activated, and no deposits or withdrawals may be processed, until the player's identity and age have been verified through document review.

// 12 Changes to This Privacy Policy

wjl2 reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, updates to Philippine privacy law, NPC guidance, or PAGCOR licensing requirements. When we make material changes to this Policy, we will notify registered players by email to the address on file and by posting a prominent notice on the wjl2 platform for a period of not less than fourteen (14) days prior to the changes taking effect.

The version number and effective date at the top of this Policy will be updated each time a revision is published. We encourage you to review this Policy periodically. Your continued use of the wjl2 platform after the effective date of any revised Policy constitutes your acceptance of the changes.

Where changes are significant enough to require fresh consent — for example, if we introduce a new processing purpose that was not covered by your original consent — we will seek that consent proactively before applying the new processing to your data.

// 13 Contact & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to report a concern about how wjl2 handles your personal data, please contact our Data Protection Officer using the details below. All privacy-related correspondence is handled exclusively by email — please do not send physical mail.

• Data Protection Officer — wjl2
• Email: [email protected]
• Subject line: DATA PRIVACY — [YOUR QUERY TYPE]
• Response time: Within 3 business days for acknowledgement; within 30 calendar days for full resolution

If you are not satisfied with wjl2's response to a data privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines at privacy.gov.ph (reference only — not a clickable link).