Privacy Policy

1. Overview & Scope

This Privacy Policy ("Policy") describes how ccjl ("ccjl," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "Player," or "User") who access or use the ccjl online gaming platform available at ccjl.app and its associated services (collectively, the "Platform").

This Policy applies to all personal data processed by ccjl in connection with your use of the Platform, including data collected during account registration, identity verification, gameplay, financial transactions, customer support interactions, and marketing communications. It applies regardless of whether you access the Platform via a web browser, mobile device, or any other means.

This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). By using the ccjl Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which form part of the overall agreement between you and ccjl.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, ccjl is the personal information controller responsible for the personal data collected through the Platform. ccjl determines the purposes and means of processing your personal data and is accountable for ensuring that such processing is carried out in accordance with applicable Philippine data privacy law.

If you have any questions, concerns, or requests relating to the processing of your personal data by ccjl, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

ccjl collects the following categories of personal data in connection with your use of the Platform:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify that you meet the 21+ age requirement);
• Gender;
• Nationality and country of residence;
• Government-issued identification number (e.g., Philippine National ID, passport, driver's licence, SSS/GSIS number);
• Username and account password (stored in encrypted form).

3.2 Contact Data

• Philippine mobile number;
• Email address;
• Residential address (province, city/municipality, barangay, street).

3.3 Financial & Transaction Data

• GCash or PayMaya account number or registered mobile number;
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where provided for withdrawal purposes;
• Deposit and withdrawal history, including amounts in Philippine Peso (PHP), timestamps, and payment method used;
• Account balance and wagering history;
• Bonus and promotional credit history.

3.4 Identity Verification (KYC) Data

• Copies of government-issued photo identification documents;
• Proof of address documents (e.g., utility bills, bank statements);
• Selfie or live photo for facial verification purposes, where required;
• Source of funds documentation, where required by anti-money laundering regulations.

3.5 Technical & Usage Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type and version;
• Session duration, pages visited, and features accessed on the Platform;
• Game play logs, including games played, wagers placed, and outcomes;
• Login timestamps and access logs.

3.6 Communications Data

• Records of your communications with ccjl customer support, including live chat transcripts and email correspondence;
• Feedback, complaints, and dispute records;
• Responses to surveys or promotional communications, where you choose to participate.

4. How We Collect Your Data

ccjl collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion;
• Automatically — through cookies, web beacons, server logs, and similar tracking technologies when you access and interact with the Platform (see Section 10 for details);
• From third-party service providers — including identity verification agencies, payment processors (e.g., GCash, PayMaya, BPI, BDO), fraud detection services, and analytics providers, where such sharing is necessary to operate the Platform;
• From regulatory and law enforcement authorities — where ccjl is required by law to receive or disclose information in connection with an investigation or compliance obligation.

5. How We Use Your Personal Data

ccjl processes your personal data for the following purposes:

ccjl will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable Philippine law.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, ccjl processes your personal data on the following legal bases:

• Contractual necessity — processing is necessary to perform our obligations under the ccjl Terms & Conditions, including account management, payment processing, and the provision of gaming services;
• Legal obligation — processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering laws, PAGCOR licensing requirements, and tax obligations;
• Legitimate interests — processing is necessary for ccjl's legitimate interests in operating a secure, fair, and commercially viable gaming platform, including fraud prevention, security monitoring, and platform improvement, provided that such interests are not overridden by your rights and freedoms;
• Consent — where ccjl relies on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Sharing Your Personal Data

ccjl does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers — GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, for the purpose of processing your deposits and withdrawals;
• Identity verification and KYC providers — third-party agencies engaged to verify your identity and age in accordance with regulatory requirements;
• Fraud prevention and security services — providers of fraud detection, risk assessment, and cybersecurity services that help protect the integrity of the ccjl Platform;
• IT and platform infrastructure providers — cloud hosting, data storage, and software service providers that support the technical operation of the Platform, all of whom are contractually bound to process your data only on ccjl's instructions;
• Regulatory and law enforcement authorities — PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where ccjl is required by law to disclose your data;
• Professional advisers — lawyers, auditors, and accountants, where necessary for the conduct of ccjl's business and subject to professional confidentiality obligations;
• Business successors — in the event of a merger, acquisition, or sale of all or part of ccjl's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

8. Data Retention

ccjl retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account and KYC data — retained for a minimum of five (5) years from the date of account closure, in accordance with PAGCOR requirements and Philippine AML regulations;
• Financial transaction records — retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act (Republic Act No. 9160, as amended);
• Customer support communications — retained for three (3) years from the date of the last interaction;
• Marketing consent records — retained for as long as you remain a registered ccjl player or until you withdraw your consent, whichever is earlier;
• Technical and usage logs — retained for up to twelve (12) months, unless a longer retention period is required for security or legal purposes.

Upon expiry of the applicable retention period, ccjl will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9. Data Security

ccjl implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ccjl Platform;
• Encryption of sensitive data at rest, including passwords (stored using industry-standard hashing algorithms) and financial account details;
• Role-based access controls ensuring that ccjl personnel can only access personal data that is necessary for their specific job function;
• Regular security audits, vulnerability assessments, and penetration testing of the Platform's infrastructure;
• Two-factor authentication (2FA) options for player accounts;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

10. Cookies & Tracking Technologies

The ccjl Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and collect usage analytics. The following types of cookies may be used:

• Strictly necessary cookies — essential for the Platform to function correctly, including session management and security tokens. These cannot be disabled;
• Functional cookies — used to remember your preferences, such as language settings and game display options;
• Analytics cookies — used to collect aggregated, anonymised data about how players use the Platform, helping ccjl improve its services;
• Security cookies — used to detect and prevent fraudulent activity, including bot detection and login anomaly monitoring.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the ccjl Platform. ccjl does not use third-party advertising cookies or share cookie data with external advertising networks.

11. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ccjl:

• Right to be informed — the right to be notified of how your personal data is being collected and processed, as set out in this Policy;
• Right of access — the right to request a copy of the personal data that ccjl holds about you;
• Right to rectification — the right to request correction of any inaccurate or incomplete personal data that ccjl holds about you;
• Right to erasure — the right to request deletion of your personal data, subject to ccjl's legal obligations to retain certain data for regulatory compliance purposes;
• Right to object — the right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to data portability — the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint — the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that ccjl has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact ccjl's Data Protection Officer using the contact details in Section 14. ccjl will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

12. Minors & Age Restriction

If ccjl discovers or has reason to believe that personal data has been collected from a person under the age of 21, ccjl will immediately suspend the relevant account, delete the associated personal data, and reverse any financial transactions associated with that account to the extent practicable. If you are a parent or guardian and believe that your child has registered on the ccjl Platform, please contact us immediately using the details in Section 14.

13. Changes to This Privacy Policy

ccjl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, ccjl will notify registered players via the email address associated with their account and/or by displaying a prominent notice on the Platform. The date of the most recent revision is always indicated at the top of this page.

Your continued use of the ccjl Platform following the posting of a revised Privacy Policy constitutes your acknowledgement of the changes and your agreement to be bound by the updated Policy. If you do not agree to the revised Policy, you must cease using the Platform and may request the closure of your account in accordance with the ccjl Terms & Conditions.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ccjl, please contact our Data Protection Officer (DPO). Our DPO is responsible for overseeing ccjl's compliance with the Data Privacy Act of 2012 and for handling all data subject requests.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe that your data privacy rights have been violated. For more information on your rights and how to file a complaint, please refer to the NPC's official resources.