superjl Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how superjl ("superjl," "we," "us," or "our") collects, uses, discloses, stores, and protects the personal data of users ("you," "Player," or "Data Subject") who access and use the superjl online gaming platform at superjl.app ("the Platform").

superjl is committed to protecting the privacy and personal data of all its users in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission (NPC). Our operations also comply with the data protection requirements of the Philippine Amusement and Gaming Corporation (PAGCOR) as part of our regulatory obligations.

By registering for a superjl account or using any part of the 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. If you do not agree with this Policy, you should not use the superjl Platform.

2. Data Controller

superjl is the data controller responsible for the personal data collected through the Platform. As data controller, superjl determines the purposes and means of processing your personal data and is accountable for ensuring such processing complies with RA 10173 and applicable regulations.

superjl has appointed a Data Protection Officer (DPO) responsible for overseeing this Policy and handling data subject inquiries and complaints. Contact details for the DPO are provided in Section 14 of this Policy.

3. Personal Data We Collect

3.1 Registration Data

When you create a superjl account, we collect the following personal data:

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify you are 21 years of age or older)
• Philippine residential address
• Valid email address
• Registered Philippine mobile number
• Username and encrypted password

3.2 Identity Verification (KYC) Data

In compliance with PAGCOR regulations and Philippine Anti-Money Laundering laws, superjl is required to verify the identity of all account holders. We collect copies of valid Philippine government-issued identification documents, which may include a PhilSys National ID, passport, UMID, or driver's license. We may also collect selfie images for facial verification purposes where required by our KYC procedures.

3.3 Financial Data

To process deposits and withdrawals, superjl collects payment-related information including GCash account references, bank account numbers (for bank transfer withdrawals), transaction amounts, and transaction history. superjl does not store full credit or debit card numbers on its own servers; card data is handled exclusively by our certified payment processing partners.

3.4 Gaming Activity Data

superjl automatically records your gaming activity, including games played, bet amounts and outcomes, session durations, deposit and withdrawal history, bonus usage, and any responsible gaming tools you activate on your account.

3.5 Technical and Device Data

When you access the Platform, we automatically collect technical data including your IP address, browser type and version, device type and operating system, referring URL, pages visited, and timestamps of Platform interactions. This data is used for fraud prevention, platform security, and service improvement purposes.

3.6 Communications Data

If you contact superjl's customer support via live chat or email, we retain records of those communications for quality assurance, dispute resolution, and regulatory compliance purposes.

4. How We Use Your Personal Data

superjl uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your superjl account
• Identity verification: Confirming your identity and age (21+) as required by PAGCOR and Philippine law
• Transaction processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other Philippine payment channels
• Gaming services: Delivering live casino, slot, bingo, and sports betting services to your account
• Regulatory compliance: Meeting our obligations under PAGCOR regulations, Philippine AML laws, and the Data Privacy Act
• Fraud prevention: Detecting and preventing unauthorized access, money laundering, bonus abuse, and other fraudulent activity
• Responsible gaming: Monitoring gaming patterns to support responsible gaming obligations and enforce self-imposed limits
• Customer support: Responding to your inquiries, complaints, and support requests
• Platform improvement: Analyzing usage patterns to improve superjl's services, features, and user experience
• Promotions and bonuses: Administering promotional offers and verifying eligibility where you have opted in to receive such communications

5. Legal Basis for Processing

superjl processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent: For non-essential communications such as promotional emails and SMS, where you have given express consent
• Contractual necessity: Processing required to fulfill the superjl user agreement, including account operation and transaction processing
• Legal obligation: Processing required to comply with PAGCOR regulations, Anti-Money Laundering Act obligations, and NPC requirements
• Legitimate interests: Fraud prevention, platform security, and service improvement activities, balanced against your privacy rights

You may withdraw consent for non-essential processing at any time by contacting superjl's Data Protection Officer. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

6. Data Sharing and Disclosure

6.1 Regulatory Authorities

superjl is legally required to share certain account and transaction data with PAGCOR as part of our operating license conditions. We are also obligated to report suspicious transactions to the Anti-Money Laundering Council (AMLC) where required under the AMLA. superjl will cooperate with law enforcement authorities in response to lawful orders and subpoenas.

6.2 Service Providers

superjl engages third-party service providers who process personal data on our behalf, including payment processors (GCash, PayMaya, banking partners), KYC and identity verification services, fraud detection providers, cloud hosting and infrastructure providers, and customer support tools. All third-party processors are required to maintain appropriate data protection standards and are bound by data processing agreements with superjl.

6.3 Game Providers

Certain limited data (such as player identifiers and session tokens) may be shared with superjl's licensed game content providers (such as JILI, PG Soft, and Pragmatic Play) for the purpose of delivering game services. These providers do not receive your full identity or payment information.

6.4 No Commercial Data Sales

superjl does not sell, rent, trade, or otherwise commercially exploit your personal data to any third party. Your information is used exclusively for the purposes described in this Policy.

7. Cookies and Tracking Technologies

superjl uses cookies and similar tracking technologies on the Platform to maintain your login session, remember your preferences, analyze Platform usage, and support fraud prevention systems. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled.
• Analytical cookies: Help us understand how users interact with the Platform so we can improve performance and user experience.
• Functional cookies: Remember your preferences (such as language and display settings) between sessions.
• Security cookies: Used to detect and prevent fraudulent logins and suspicious activity on your superjl account.

You may control non-essential cookies through your browser settings. Disabling strictly necessary cookies may impair the functionality of the superjl Platform.

8. Data Retention

superjl retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law. Specifically:

• Account and KYC data: retained for a minimum of five (5) years after account closure, as required under PAGCOR and AML regulations
• Transaction records: retained for a minimum of five (5) years under the Anti-Money Laundering Act
• Gaming activity logs: retained for three (3) years for regulatory audit and dispute resolution purposes
• Customer support communications: retained for two (2) years
• Technical logs (IP, device data): retained for twelve (12) months for fraud detection purposes

Upon expiration of the applicable retention period, superjl will securely destroy or anonymize your personal data in accordance with NPC-approved data disposal procedures.

9. Data Security

superjl implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit TLS/SSL encryption for all data in transit between your device and superjl's servers
• AES-256 encryption for sensitive data at rest, including passwords (stored as salted cryptographic hashes) and payment references
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Multi-factor authentication requirements for superjl staff accessing production systems
• Continuous automated monitoring for security anomalies and unauthorized access attempts
• Regular third-party penetration testing and security audits of the superjl Platform
• Physical security controls for data centre facilities hosting superjl infrastructure

10. Your Rights as a Data Subject

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

• Right to be informed: The right to know what personal data superjl collects about you and how it is processed
• Right of access: The right to obtain a copy of your personal data held by superjl
• Right to correction: The right to have inaccurate or incomplete personal data corrected
• Right to erasure: The right to request deletion of your personal data, subject to legal retention obligations
• Right to object: The right to object to processing of your personal data for certain purposes, including direct marketing
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated

To exercise any of these rights, please contact superjl's Data Protection Officer using the contact information in Section 14. superjl will respond to all verified data subject requests within fifteen (15) business days of receipt.

11. Children's Privacy

The superjl Platform is strictly restricted to adults aged twenty-one (21) years and above. superjl does not knowingly collect personal data from persons under the age of 21. If superjl discovers that a registered account belongs to a person under 21, the account will be immediately suspended, all data associated with that account will be deleted in accordance with applicable law, and any deposits will be returned where legally permissible.

Parents and guardians who believe a minor may have created a superjl account should contact our Data Protection Officer immediately using the contact details in Section 14.

12. International Data Transfers

In certain circumstances, your personal data may be transferred to, or processed by, parties located outside the Philippines — for example, when using international payment processors or cloud infrastructure providers with data centres in other countries. superjl ensures that any international transfers of personal data are conducted in compliance with the Data Privacy Act and NPC guidelines, including the use of appropriate contractual safeguards or adequacy determinations.

superjl will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate safeguards and obtaining any required regulatory approvals.

13. Updates to This Privacy Policy

superjl may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes will be communicated to registered users via email to the address on file and/or a prominent notice on the Platform, at least fourteen (14) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. Continued use of the superjl Platform after the effective date of any update constitutes your acceptance of the revised Policy.

14. Contact and Data Protection Officer

For questions, requests to exercise your data subject rights, or complaints regarding this Privacy Policy or superjl's data processing practices, please contact our Data Protection Officer:

Data Protection Officer — superjl

Email: support@superjl.app

Live Chat: Available 24/7 via the superjl Platform

Peak support hours: 6 PM – 2 AM Philippine Standard Time

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe that your data privacy rights under RA 10173 have been violated.