abcjl Privacy Policy

1Introduction

1.1 abcjl is committed to protecting the privacy and personal data of every individual who interacts with our Platform. This Privacy Policy has been prepared in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, its Implementing Rules and Regulations, and the circulars and advisories issued by the National Privacy Commission (NPC).

1.2 This Privacy Policy applies to all personal data collected, processed, stored, or shared by abcjl in connection with the operation of abcjl.app, including data collected during account registration, identity verification, gameplay, payment processing, customer support interactions, and marketing communications.

1.3 By accessing abcjl.app, creating an account, or using any service offered through the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2Data Controller

2.1 abcjl acts as the Personal Information Controller (PIC) for all personal data collected through abcjl.app, as defined under Republic Act No. 10173. As PIC, abcjl determines the purposes for which, and the means by which, personal data is processed.

2.2 Where abcjl engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification services, or analytics providers — those parties act as Personal Information Processors (PIPs) under written data processing agreements that bind them to appropriate data protection standards consistent with Philippine law.

2.3 abcjl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection regulations. Contact details for the DPO are provided in Section 14.

3Personal Data We Collect

3.1 abcjl collects personal data in the categories set out below. The specific data collected depends on how you interact with the Platform and the services you use.

3.2 abcjl does not intentionally collect sensitive personal information — as defined under Section 3(l) of Republic Act No. 10173 — unless strictly necessary for identity verification, age confirmation, or compliance with a specific regulatory obligation. Where sensitive personal information is collected, additional safeguards apply and explicit consent is obtained.

4How We Collect Personal Data

abcjl collects personal data through the following channels:

• Direct submission: Data you provide when creating an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access or use abcjl.app through cookies, web beacons, log files, and similar tracking technologies (see Section 10).
• Third-party sources: Identity verification data from KYC service providers; fraud risk data from anti-money laundering and fraud detection services; and payment confirmation data from payment processors such as GCash and Maya.
• Regulatory sources: Information received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other government authorities in the exercise of their regulatory functions.

5Purpose & Legal Basis for Processing

5.1 abcjl processes personal data only for specified, legitimate purposes. The primary purposes and corresponding legal bases under Republic Act No. 10173 are as follows:

1. Account registration and management — Processing is necessary for the performance of the contract between you and abcjl (i.e., the Terms and Conditions you agree to upon registration).
2. Identity and age verification (KYC) — Processing is required for compliance with PAGCOR regulations and Philippine anti-money laundering laws mandating player identification and age verification (21+).
3. Payment processing and fraud prevention — Processing is necessary for contract performance and for the legitimate interests of abcjl and its players in preventing financial fraud and unauthorized transactions.
4. Gameplay and transaction records — Processing is necessary for contract performance and for compliance with regulatory record-keeping obligations.
5. Responsible gaming monitoring — Processing is carried out in the legitimate interest of player welfare and in compliance with PAGCOR responsible gaming requirements.
6. Customer support — Processing is necessary for contract performance and abcjl's legitimate interest in resolving player queries efficiently.
7. Marketing communications — Processing is based on your explicit consent at the time of registration or at the time you opt in to marketing communications. You may withdraw consent at any time.
8. Legal and regulatory compliance — Processing is required to fulfill abcjl's obligations under Philippine law, including PAGCOR licensing conditions, AMLC reporting requirements, and NPC compliance obligations.

6Data Sharing with Third Parties

6.1 abcjl does not sell, rent, or otherwise disclose personal data to third parties for their own commercial purposes. Data sharing is limited to the following categories of recipients and purposes:

• Payment processors (GCash, Maya, BPI, BDO, Metrobank, and other integrated payment providers): Sharing is limited to transaction data necessary to process deposits and withdrawals. Payment processors are bound by their own privacy obligations and applicable financial regulations.
• KYC and identity verification providers: Personal data submitted during the KYC process is shared with certified third-party identity verification services to confirm your identity and age. These providers operate under strict data processing agreements with abcjl.
• Fraud detection and anti-money laundering services: Technical data, transaction patterns, and identity data may be shared with AML compliance services and fraud detection platforms to identify and prevent illicit activity on the Platform.
• Game software providers: Gameplay data (such as session identifiers and bet amounts) may be shared with game developers or platform operators whose titles are available on abcjl, where technically necessary to deliver the game service.
• Regulatory authorities: abcjl will disclose personal data to PAGCOR, the AMLC, the NPC, or any other competent Philippine government authority when required by law, regulation, court order, or official investigation.
• Professional advisors: Legal counsel, auditors, and compliance consultants may have access to personal data under appropriate confidentiality obligations where necessary to provide their services to abcjl.

6.2 In the event that abcjl undergoes a corporate restructuring, merger, acquisition, or sale of assets, personal data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained. Affected players will be notified prior to such a transfer.

7Data Retention

7.1 abcjl retains personal data for no longer than is necessary for the purposes for which it was collected, subject to any applicable legal or regulatory retention requirements. The key retention periods are as follows:

7.2 Upon expiry of the applicable retention period, personal data will be securely deleted, anonymized, or pseudonymized in accordance with abcjl's data disposal procedures. Anonymized or aggregated data that cannot be used to identify any individual may be retained for longer periods for statistical and analytical purposes.

8Security Measures

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

• 256-bit SSL/TLS encryption on all data transmissions between your device and abcjl's servers;
• Encryption at rest for all stored personal data and financial records;
• Hashed and salted password storage — abcjl never stores your password in plain text;
• Two-factor authentication (2FA) available to all Players and required for all staff accounts;
• Role-based access controls limiting employee access to personal data to the minimum necessary for their job function;
• Regular security audits and penetration testing conducted by independent third-party security specialists;
• Intrusion detection and anomaly monitoring systems operating continuously across abcjl's infrastructure;
• Staff data protection training conducted at onboarding and on a regular recurring basis.

8.2 In the event of a personal data breach that is reasonably likely to harm your interests, abcjl will notify you and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03 on mandatory data breach notification.

9Your Rights as a Data Subject

9.1 As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by abcjl:

9.2 To exercise any of the rights listed above, contact abcjl's Data Protection Officer at the address provided in Section 14. abcjl will respond to all verified data subject requests within fifteen (15) working days of receipt. Complex or multiple requests may require additional time; abcjl will inform you if an extension is needed.

9.3 abcjl will not charge a fee for responding to a data subject request unless the request is manifestly unfounded or excessive. In such cases, a reasonable administrative fee may be applied.

9.4 If you believe that abcjl has failed to comply with your rights or any requirement of Republic Act No. 10173, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

10Cookies & Tracking Technologies

10.1 abcjl uses cookies and similar technologies (including web beacons, pixel tags, and local storage objects) on abcjl.app to support Platform functionality, analyze usage patterns, and deliver relevant content. The categories of cookies used are described below:

10.2 You may manage your cookie preferences at any time through your browser settings. Most browsers allow you to block or delete cookies through their privacy settings. Please note that blocking essential cookies will affect Platform functionality. Instructions for managing cookies in common browsers are widely available from the respective browser providers.

10.3 abcjl does not use cookies or tracking technologies to deliver third-party advertising on abcjl.app, nor does it participate in cross-site advertising networks that track your browsing behavior across unrelated websites.

11Minors and Age Restriction

11.1 abcjl strictly prohibits the use of the Platform by individuals under twenty-one (21) years of age, in accordance with PAGCOR regulations governing online gambling in the Philippines. This is a hard regulatory requirement, not merely a guideline.

11.2 abcjl does not knowingly collect personal data from individuals under 21 years of age. Age is collected and verified during the registration process, and KYC documentation confirming age is required before full account access and withdrawal privileges are granted.

11.3 If abcjl becomes aware that personal data has been collected from an individual who is below the age of 21 — whether through registration, payment processing, or any other means — that Account will be immediately suspended, all related data will be secured, and the matter will be handled in accordance with applicable regulatory requirements. Any funds associated with such an Account will be dealt with in compliance with PAGCOR directives.

11.4 Parents or legal guardians who believe that a minor has attempted to register with or use abcjl are encouraged to contact support immediately so that the matter can be investigated and resolved without delay.

12Cross-Border Data Transfers

12.1 The abcjl Platform may use service providers or infrastructure located outside the Philippines — for example, cloud hosting providers, game content delivery networks, or KYC verification services. Where personal data is transferred to recipients in countries outside the Philippines, abcjl takes the following steps to ensure adequate protection:

• Executing data processing agreements incorporating the standard contractual clauses or equivalent safeguards required by the NPC;
• Transferring data only to recipients in countries with an adequate level of data protection as determined by the NPC or other competent authority;
• Applying contractual obligations on overseas processors that mirror abcjl's obligations under Republic Act No. 10173.

12.2 Where cross-border transfers involve financial data processed by payment providers such as GCash or Maya, such transfers are governed by the relevant payment provider's own privacy frameworks and applicable BSP (Bangko Sentral ng Pilipinas) regulations.

13Changes to This Privacy Policy

13.1 abcjl reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be communicated to registered Players via email to the address on file and/or by displaying a prominent notice on abcjl.app at least seven (7) days prior to the changes taking effect.

13.2 The effective date at the top of this document indicates when the current version was last reviewed and updated. We encourage you to revisit this page periodically to stay informed of any updates.

13.3 Your continued use of the abcjl Platform after any amendment to this Privacy Policy takes effect constitutes your acceptance of the updated Policy. If you do not accept a material amendment, you may close your Account by contacting abcjl's support team, and your personal data will be handled in accordance with this Policy as it stood at the time of closure.

14Contact & Data Protection Officer

14.1 For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by abcjl, please contact our Data Protection Officer (DPO) through any of the following channels:

• Email (DPO): [email protected] — please mark your message "Attention: Data Protection Officer"
• Live Chat: Available 24/7 on abcjl.app — identify your query as a privacy or data protection matter and it will be routed to the DPO team.
• Postal Address: Correspondence addressed to the Data Protection Officer, abcjl, Philippines. Please allow additional processing time for postal communications.

14.2 If you are unsatisfied with abcjl's response to a privacy concern or data subject request, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. The NPC's official complaint mechanism and contact details are available through the NPC's published resources.