Privacy Policy — 88lj Data Protection Commitment

Last Updated: January 1, 2026 | Effective Date: January 1, 2026

1. Introduction and Scope

This Privacy Policy ("Policy") governs the collection, processing, storage, use, disclosure, and protection of personal information and personal data provided by you ("User," "Player," "you," or "your") to 88lj ("88lj," "we," "us," or "our"), a PAGCOR-regulated online gaming platform operating at https://88lj.cam and associated mobile applications. This Policy is established in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and all applicable issuances of the National Privacy Commission (NPC) of the Philippines, as well as PAGCOR's regulatory requirements governing the online gaming industry in the Philippines.

By creating an account on the 88lj platform, accessing our website, using our services, or providing your personal information to us in any manner, you acknowledge that you have read, understood, and consent to the collection, processing, and use of your personal data as described in this Privacy Policy. You also acknowledge that you have been informed of your rights as a data subject under the Data Privacy Act of 2012 and understand how to exercise those rights.

2. Personal Information We Collect

2.1 Information You Provide Directly

When you register for an 88lj account, make deposits, request withdrawals, participate in promotions, or communicate with our customer support team, we collect various categories of personal information that you voluntarily provide to us, including but not limited to:

• Identity Information: Full legal name as it appears on government-issued identification documents, date of birth, gender, nationality, and copies of government-issued IDs (Philippine passport, driver's license, UMID, SSS ID, postal ID, or other valid identification documents) submitted for account verification purposes.
• Contact Information: Residential address (street address, barangay, city/municipality, province, postal code), email address, mobile phone number, and other contact details.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet information (GCash account number, Maya account details), cryptocurrency wallet addresses, payment card information (card number, expiration date, CVV), transaction history, deposit and withdrawal records, and financial documentation submitted for verification purposes such as bank statements or proof of income.
• Account Credentials: Username, password (stored in encrypted format), security questions and answers, two-factor authentication settings, and session authentication tokens.
• Communication Records: Contents of your communications with our customer support team via email, live chat, phone calls, or other communication channels, including support tickets, complaint records, and feedback submissions.
• Marketing Preferences: Your communication preferences regarding promotional emails, SMS notifications, push notifications, and other marketing communications.

2.2 Information Collected Automatically

When you access or use the 88lj platform, we automatically collect certain information through cookies, web beacons, server logs, and similar tracking technologies:

• Device Information: Device type, model, operating system version, device identifiers (such as IP address, device ID, advertising ID), browser type and version, screen resolution, and device language settings.
• Usage Information: Pages visited, features accessed, games played, betting patterns, session duration, click-stream data, referring URLs, search queries entered on our platform, and general browsing behavior.
• Location Data: IP address-based geolocation information to verify that you are physically located within the Philippines when accessing our services, in compliance with PAGCOR's territorial jurisdiction requirements.
• Transaction Data: Details of your gaming activity including wagers placed, games played, wins and losses, bonus claims, deposit and withdrawal transactions, timestamps, and account balance changes.
• Technical Information: Server log data including timestamps of access, HTTP request methods, response status codes, browser cookies, and session identifiers used for platform security and fraud prevention.

2.3 Information from Third-Party Sources

We may receive information about you from third-party sources including payment processors (GCash, Maya, bank partners), identity verification services, fraud prevention agencies, credit reference agencies where legally permitted, public databases and registers, and marketing partners or affiliates through whom you accessed the 88lj platform. This information is combined with data you provide directly to verify your identity, prevent fraud, comply with regulatory obligations, and improve our services.

3. How We Use Your Personal Information

3.1 Lawful Bases for Processing

88lj processes your personal information on the basis of the following lawful grounds under the Data Privacy Act of 2012:

• Consent: You have provided explicit, informed, and freely given consent for specific processing activities, particularly for marketing communications and non-essential cookies.
• Contractual Necessity: Processing is necessary for the performance of our Terms and Conditions agreement with you, including account creation, transaction processing, and service delivery.
• Legal Obligation: Processing is required to comply with Philippine laws, PAGCOR regulations, Anti-Money Laundering Act (AMLA) requirements, Know Your Customer (KYC) obligations, tax reporting obligations, and other legal or regulatory requirements.
• Legitimate Interests: Processing is necessary for our legitimate business interests including fraud prevention, security monitoring, platform optimization, business analytics, and risk management, provided such interests are not overridden by your fundamental rights and freedoms.

3.2 Purposes of Data Processing

We use your personal information for the following specific purposes:

• Account Management: Creating and maintaining your 88lj account, authenticating your identity when you log in, managing your account settings and preferences, processing account updates and modifications, and providing customer support services.
• Transaction Processing: Processing deposits, withdrawals, and other financial transactions; maintaining accurate transaction records; calculating winnings and losses; processing bonus payments and promotional rewards; and reconciling your account balance.
• Regulatory Compliance: Verifying your identity and age to ensure you meet the minimum age requirement of 21 years; conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures; complying with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) obligations; reporting suspicious transactions to the Anti-Money Laundering Council (AMLC); maintaining transaction records as required by PAGCOR and other regulatory authorities; and cooperating with law enforcement investigations when legally required.
• Fraud Prevention and Security: Detecting and preventing fraudulent activity, account takeovers, money laundering, collusion, bonus abuse, and other prohibited activities; monitoring for unusual betting patterns or suspicious transactions; protecting the security and integrity of the 88lj platform; and enforcing our Terms and Conditions and game rules.
• Service Improvement: Analyzing usage patterns and player behavior to improve our games, features, and user experience; conducting research and analytics to understand player preferences; testing new features and functionality; optimizing platform performance and reliability; and personalizing your gaming experience.
• Marketing and Communications: Sending you promotional offers, bonus notifications, and marketing communications about new games, features, and services, subject to your communication preferences; providing personalized recommendations based on your gaming preferences; and conducting customer satisfaction surveys and feedback requests.
• Responsible Gaming: Monitoring your gaming behavior for signs of problem gambling; enforcing deposit limits, loss limits, and session time limits you have set; implementing cooling-off periods and self-exclusion measures; and providing access to responsible gaming resources and support services.

4. How We Share Your Personal Information

4.1 Disclosure to Third Parties

88lj does not sell, rent, or trade your personal information to third parties for their own marketing purposes. However, we may disclose your personal information to the following categories of recipients when necessary for the purposes described in this Policy:

• Service Providers and Business Partners: Payment processors including GCash, Maya, banks, and cryptocurrency platforms that process your deposits and withdrawals; identity verification services that conduct KYC and AML checks; cloud hosting providers that store our databases and application servers; customer support platforms that manage our support ticket system and live chat services; email service providers that deliver transactional and marketing emails; SMS gateway providers for mobile notifications; and analytics platforms that help us understand usage patterns.
• Gaming Suppliers and Software Providers: Game developers and casino software providers (such as JILI, Evolution Gaming, Pragmatic Play, and other suppliers) who power the games available on the 88lj platform and may collect certain gameplay data for their own analytics, compliance, and fraud prevention purposes.
• Regulatory Authorities: Philippine Amusement and Gaming Corporation (PAGCOR) for regulatory reporting and compliance verification; Anti-Money Laundering Council (AMLC) for suspicious transaction reports; National Privacy Commission (NPC) in response to valid data subject complaints or requests; Bureau of Internal Revenue (BIR) for tax reporting purposes; and other government agencies when legally required by court orders, subpoenas, or lawful regulatory demands.
• Legal and Professional Advisors: Legal counsel, accountants, auditors, and consultants who provide professional services to 88lj and are bound by confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy proceedings, your personal information may be transferred to the acquiring entity or successor organization, subject to the same privacy protections outlined in this Policy.

4.2 International Data Transfers

Some of our service providers, particularly cloud hosting providers and software platforms, may be located outside the Philippines and may process your personal data in jurisdictions such as Singapore, the United States, or the European Union. We ensure that such international transfers are conducted in accordance with the Data Privacy Act of 2012 and NPC Circular No. 16-03 by implementing appropriate safeguards, including Standard Contractual Clauses, ensuring the recipient country has adequate data protection laws, or obtaining your explicit consent where required.

5. Data Security and Protection Measures

88lj implements robust technical, organizational, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, destruction, loss, or misuse. Our data security practices include:

• Encryption: All sensitive data including passwords, financial information, and personal identification documents are encrypted using industry-standard encryption protocols (AES-256 encryption for stored data and TLS 1.2 or higher for data in transit).
• Access Controls: Strict role-based access controls ensure that only authorized personnel with a legitimate business need can access personal data. All employee access is logged and monitored.
• Network Security: Firewalls, intrusion detection systems, and regular security audits protect our infrastructure from external threats and cyberattacks.
• Secure Data Centers: Personal data is stored in secure, ISO 27001-certified data centers with 24/7 physical security, environmental controls, redundant power and cooling systems, and disaster recovery capabilities.
• Employee Training: All employees and contractors undergo mandatory data privacy and security training and are bound by strict confidentiality agreements.
• Incident Response: We maintain an incident response plan to quickly detect, contain, and respond to data breaches or security incidents, and will notify affected individuals and the National Privacy Commission as required by law.

Despite these measures, no method of electronic transmission or storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify us if you suspect unauthorized access to your account.

6. Data Retention and Deletion

88lj retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests. Specific retention periods include:

• Active Accounts: Personal information for active accounts is retained for the duration of your relationship with 88lj and for as long as your account remains open.
• Closed Accounts: Following account closure, we retain identity verification records, transaction history, and other essential data for a minimum of five (5) years to comply with PAGCOR record-keeping requirements and Anti-Money Laundering Act obligations.
• Transaction Records: Financial transaction records, deposit and withdrawal history, and gaming activity logs are retained for at least five (5) years from the date of the transaction for regulatory compliance and dispute resolution purposes.
• Communication Records: Customer support communications, complaint records, and correspondence are retained for three (3) years for quality assurance and dispute resolution purposes.
• Marketing Data: If you opt out of marketing communications, we will retain a record of your opt-out preference indefinitely to ensure we do not contact you again, but will delete other marketing-related data within one (1) year of your last interaction with marketing content.

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with our data retention and disposal policies. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

7. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

• Right to Be Informed: You have the right to be informed about the collection, processing, and use of your personal data, which is fulfilled through this Privacy Policy and account registration disclosures.
• Right to Access: You have the right to request access to your personal information held by 88lj and to obtain copies of such data in a commonly used electronic format.
• Right to Rectification: You have the right to correct inaccurate, incomplete, or outdated personal information. You can update your account information directly through your account settings or by contacting customer support.
• Right to Erasure (Right to Be Forgotten): You have the right to request deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes it was collected, when you withdraw consent, or when the data has been unlawfully processed. This right is subject to legal and regulatory retention requirements.
• Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes or when processing is based on legitimate interests. You can opt out of marketing communications at any time by clicking the unsubscribe link in emails or adjusting your communication preferences in your account settings.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another service provider where technically feasible.
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission if you believe your data privacy rights have been violated. Contact the NPC at [email protected] or visit their website at https://www.privacy.gov.ph.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 11 of this Policy. We will respond to your request within fifteen (15) days as required by NPC regulations, or inform you if additional time is needed to complete your request.

8. Cookies and Tracking Technologies

88lj uses cookies, web beacons, pixels, and similar tracking technologies to enhance your user experience, analyze platform usage, remember your preferences, and deliver personalized content. Cookies are small text files stored on your device that help us recognize you when you return to our platform.

8.1 Types of Cookies We Use

• Essential Cookies: Required for the platform to function properly, including session management, authentication, security features, and load balancing. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Collect anonymous information about how you use the platform, including pages visited, time spent on pages, and error messages encountered. This helps us improve platform performance and user experience.
• Functionality Cookies: Remember your preferences such as language selection, display settings, and account preferences to provide a more personalized experience.
• Marketing Cookies: Track your browsing behavior across our platform to deliver targeted advertising and promotional content based on your interests. These cookies require your consent and can be disabled through your cookie preferences.

8.2 Managing Cookies

You can manage your cookie preferences by adjusting your browser settings to refuse all or some cookies, delete existing cookies, or receive notifications when cookies are being set. However, disabling essential cookies may affect your ability to use certain features of the 88lj platform. Please refer to your browser's help documentation for instructions on managing cookies.

9. Children's Privacy

The 88lj platform is intended exclusively for adults aged twenty-one (21) years or older in accordance with Philippine gambling laws and PAGCOR regulations. We do not knowingly collect, process, or solicit personal information from individuals under the age of 21. If we discover that we have inadvertently collected personal data from a minor, we will immediately delete such information from our systems and terminate the associated account. If you believe a minor has provided personal information to 88lj, please contact our Data Protection Officer immediately using the contact details provided below.

10. Changes to This Privacy Policy

88lj reserves the right to modify, update, or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. Any material changes to this Policy will be communicated to you via email notification sent to your registered email address or through a prominent notice on the 88lj platform. The "Last Updated" date at the top of this Policy indicates when the most recent revisions were made. Your continued use of the 88lj platform following any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your personal information.

11. Contact Information and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal information, or the exercise of your data subject rights, please contact our Data Protection Officer:

• Data Protection Officer
• Email: [email protected]
• General Customer Support Email: [email protected]
• Live Chat: Available 24/7 through your account dashboard (please mention "Privacy Request" to be routed to our Data Protection team)
• Response Time: We will respond to all privacy-related inquiries within fifteen (15) business days