abjl Privacy Policy

1 Who We Are

abjl is a Philippines-facing online casino and sportsbook platform accessible at abjl.net. We operate in compliance with applicable Philippine gaming regulations, including guidelines issued by the Philippine Amusement and Gaming Corporation (PAGCOR). In the context of this Privacy Policy, "abjl," "we," "us," and "our" refer to the operator of the abjl platform.

abjl acts as the personal information controller (PIC) in respect of the personal data it collects directly from players and platform users. Where abjl engages third-party service providers to process data on its behalf, those providers act as personal information processors (PIPs) under abjl's instruction and are bound by appropriate data processing agreements.

abjl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. Contact details for the DPO are provided in Section 14 of this document.

2 Personal Data We Collect

abjl collects the following categories of personal data in connection with the operation of its platform and the delivery of its services to Filipino players:

2.1 Identity & Registration Data

• Full legal name (first name, middle name, last name)
• Date of birth (for age verification — players must be 21 or older)
• Gender
• Nationality and country of residence
• Government-issued ID details (ID type, ID number, expiry date)
• Selfie or live photo submitted for facial verification

2.2 Contact Data

• Email address
• Mobile phone number (Philippine format)
• Residential address (barangay, city/municipality, province, ZIP code)

2.3 Financial & Transaction Data

• Deposit and withdrawal records, including amounts in PHP, timestamps, and payment channel used
• GCash number, Maya/PayMaya account reference, bank account details (BPI, BDO, Metrobank), or other linked payment method identifiers
• Wagering history: games played, bet amounts, winnings, and losses
• Bonus and promotional credit activity
• Source of funds declarations where required for AML compliance

2.4 Technical & Usage Data

• IP address and geolocation data
• Device type, operating system, and browser information
• Session duration, login timestamps, and platform navigation data
• Device fingerprint identifiers used for duplicate account detection
• Crash reports and error logs submitted automatically by the platform

2.5 Communication Data

• Records of communications between you and abjl's support team, including chat transcripts, email correspondence, and support ticket content
• Survey responses and feedback submitted voluntarily through the platform
• Marketing preferences and communication opt-in/opt-out records

3 How We Collect Your Data

abjl collects personal data through the following channels and mechanisms:

• Direct registration: Information you provide when creating your abjl account, including your name, date of birth, email, and mobile number.
• KYC document submission: Government-issued ID scans and selfie photos uploaded through the platform's identity verification portal.
• Payment transactions: Financial data captured when you make deposits or request withdrawals via GCash, Maya, BPI, BDO, Metrobank, InstaPay, PesoNet, GrabPay, or 7-Eleven CLiQQ.
• Platform usage: Technical data collected automatically through cookies, log files, and analytics tools as you browse and interact with abjl.
• Support interactions: Data you share when contacting the abjl support team via the Support page, live chat, or email.
• Third-party verification services: Identity and address verification data received from licensed KYC and fraud-prevention providers engaged by abjl.
• Regulatory and compliance sources: Data received from PAGCOR, Philippine law enforcement, or other government bodies in connection with regulatory requests or legal obligations.

4 How We Use Your Personal Data

abjl processes your personal data for the following specific and lawful purposes:

5 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, abjl relies on the following legal bases for processing your personal data:

• Contractual necessity: Processing required to register your account, process transactions, and deliver gaming services as agreed in the abjl Terms & Conditions.
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws.
• Legitimate interests: Processing necessary for fraud prevention, responsible gaming monitoring, duplicate account detection, platform security, and general business operations — provided such interests are not overridden by your data privacy rights.
• Consent: Processing for marketing communications and optional platform features, where you have provided freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without penalty by contacting abjl via the Support page.

6 Data Sharing & Disclosure

abjl does not sell, rent, or trade your personal data. We may share your information only in the circumstances described below:

6.1 Service Providers & Processors

abjl engages third-party providers to support platform operations, including KYC verification partners, payment processors (GCash, Maya, BPI, BDO, Metrobank, and others), game content suppliers, cloud infrastructure providers, and customer support software vendors. These providers process your data solely under abjl's instruction and are bound by data processing agreements consistent with Philippine data privacy requirements.

6.2 Regulatory & Law Enforcement Authorities

abjl will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), Philippine law enforcement agencies, or other competent government bodies where required by law, court order, or regulatory directive. abjl will endeavor to notify affected players of such disclosures where legally permissible.

6.3 Corporate Transactions

In the event of a merger, acquisition, or sale of abjl's business assets, player data may be transferred to the acquiring entity, subject to appropriate data privacy safeguards and notification to affected players as required by the NPC.

6.4 Professional Advisers

abjl may share personal data with its legal, financial, and compliance advisers on a strictly confidential and need-to-know basis for the purpose of obtaining professional advice.

7 Cookies & Tracking Technologies

abjl uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small data file placed on your device when you access the abjl website. The types of cookies used by abjl are as follows:

You may manage your cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies may prevent certain platform features from functioning correctly. For full cookie management, contact abjl via the Support page.

8 Data Retention

abjl retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with abjl's data disposal procedures. Data subject to an active legal hold, regulatory investigation, or unresolved dispute may be retained beyond the standard retention period until the matter is resolved.

9 Data Security

abjl implements appropriate technical and organisational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data transmitted between your device and abjl's servers is encrypted using TLS (Transport Layer Security). Sensitive data at rest, including payment details and KYC documents, is encrypted using AES-256 or equivalent standards.
• Access controls: Access to personal data is restricted to authorized abjl personnel and service providers on a strict need-to-know basis. All access is logged and reviewed regularly.
• Two-factor authentication: abjl offers and encourages two-factor authentication (2FA) for player accounts to reduce the risk of unauthorized access.
• Staff training: All abjl personnel who handle personal data undergo mandatory data privacy training aligned with the requirements of the Data Privacy Act of 2012.
• Penetration testing: abjl conducts periodic security assessments and penetration testing of its platform infrastructure.
• Incident response: abjl maintains a documented data breach response procedure. In the event of a personal data breach, affected players and the National Privacy Commission will be notified within the timeframes prescribed by Philippine law.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights in relation to your personal data held by abjl:

• Right to be informed: You have the right to be told what personal data abjl holds about you, how it is used, and with whom it is shared. This Privacy Policy fulfills that obligation.
• Right to access: You may request a copy of the personal data abjl holds about you in a structured, commonly used format.
• Right to rectification: If any personal data held by abjl is inaccurate or incomplete, you have the right to request that it be corrected.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to abjl's legal and regulatory retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests, subject to applicable legal grounds.
• Right to data portability: Where technically feasible, you may request that your personal data be transferred to you or to another platform in a structured, machine-readable format.
• Right to lodge a complaint: If you believe abjl has violated your data privacy rights, you may file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, contact abjl's Data Protection Officer via the Support page. abjl will respond to verifiable data subject requests within 15 business days of receipt. Where a request is complex or involves a large volume of data, abjl may extend the response period by a further 15 business days with prior notice to you.

11 Children's Privacy & Age Restriction

The abjl platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming law. abjl does not knowingly collect personal data from individuals under the age of 21.

If abjl discovers or is notified that it has inadvertently collected personal data from a player who is under 21 years of age, abjl will immediately:

• Suspend and permanently close the relevant account.
• Refund any net deposits made to the account via the original payment channel.
• Void any winnings generated by the account.
• Securely delete all personal data associated with the account beyond what is required to be retained for regulatory compliance purposes.

12 Cross-Border Data Transfers

abjl primarily stores and processes personal data within the Philippines or in data centers that meet equivalent data protection standards. In certain operational contexts — such as the use of globally hosted cloud infrastructure, international KYC verification providers, or game content suppliers based outside the Philippines — your personal data may be transferred to and processed in jurisdictions outside the Philippines.

Where such cross-border transfers occur, abjl ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual data processing agreements incorporating the standard clauses required under NPC regulations.
• Transfer to jurisdictions recognized by the NPC as providing adequate levels of data protection.
• Binding corporate rules where transfers occur within a group of companies.

By using the abjl platform and agreeing to this Privacy Policy, you acknowledge and consent to the cross-border transfer of your personal data under the safeguards described above.

13 Updates to This Privacy Policy

abjl reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, platform operations, or data processing practices. Material changes to this Policy will be communicated to registered players via email notification or a prominent platform notice prior to the changes taking effect.

The effective date displayed at the top of this document reflects the date of the most recent revision. We encourage you to review this Privacy Policy periodically to remain informed of how abjl protects and uses your personal data. Your continued use of the abjl platform after the effective date of any update constitutes acceptance of the revised Privacy Policy.

14 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by abjl, you may contact our Data Protection Officer (DPO) through the following channels:

• Support Page: abjl.net/support
• Email (plain text — not a link): [email protected]

If you are not satisfied with abjl's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC): privacy.gov.ph
• NPC Complaints: [email protected] (reference only — not an abjl link)

abjl is committed to resolving all data privacy concerns promptly and transparently. Our DPO will acknowledge receipt of your query within 2 business days and provide a substantive response within 15 business days.