Privacy Policy

1 Introduction and Scope

This Policy describes how ace jl ("ace jl," "we," "us," "our") collects, uses, stores, shares, and protects personal data relating to players, prospective players, and visitors to the ace jl platform ("you," "your," "data subject"). It also explains the rights available to you under Philippine law and how to exercise them.

This Policy applies to all personal data processed by ace jl regardless of the medium through which it is collected — whether through the acejl.win website, any future mobile application, live chat communications, email correspondence, or any other channel through which you interact with ace jl.

This Policy should be read alongside ace jl's Terms and Conditions and Responsible Gaming Policy, which together govern the overall relationship between ace jl and its players.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, ace jl acts as the Personal Information Controller in respect of personal data collected through the ace jl platform. This means ace jl determines the purposes for which your personal data is processed and the means by which that processing is carried out.

Where ace jl engages third-party service providers to process data on its behalf (for example, payment processors, cloud hosting providers, and anti-fraud service providers), those parties act as Personal Information Processors and are contractually bound by data processing agreements that require them to process data only on ace jl's instructions and in accordance with applicable Philippine privacy law.

For all privacy-related queries, requests, and complaints, you may contact ace jl's designated Data Privacy Officer (DPO) through the channels set out in Section 15 of this Policy.

3 Personal Data We Collect

ace jl collects personal data across several categories depending on your level of engagement with the platform. The table below summarises the categories of data collected and representative examples within each category.

3.1 Sensitive Personal Information

Certain data collected by ace jl during the KYC process — including government-issued ID numbers — may constitute sensitive personal information under the Data Privacy Act. ace jl applies heightened protection to sensitive personal information, including stricter access controls, encryption at rest, and documented retention schedules. Sensitive personal information is processed only where a specific legal basis exists, as described in Section 6.

4 How We Collect Your Data

4.1 Data You Provide Directly

The majority of personal data ace jl holds about you is data you provide directly when you register an account, complete KYC verification, make deposits and withdrawals, interact with customer support, participate in promotions, or update your account settings.

4.2 Data Collected Automatically

When you visit acejl.win, certain technical and usage data is collected automatically through server logs, cookies, and similar technologies. This includes your IP address, device identifiers, browser information, and session data. This data is collected to maintain platform security, analyse performance, and prevent fraud. See Section 10 for detailed information about cookie use.

4.3 Data from Third Parties

ace jl may receive personal data about you from the following categories of third parties:

• Payment processors (GCash, Maya, BPI, BDO, and others) who confirm the status and ownership of your payment account for transaction verification purposes;
• Identity verification services used to cross-reference submitted KYC documents against authoritative Philippine identity databases;
• Fraud and AML screening providers who check player details against regulatory watchlists in compliance with the Anti-Money Laundering Act (Republic Act No. 9160, as amended);
• PAGCOR and other regulatory authorities, where ace jl is required by its licensing conditions to receive information about players involved in regulatory proceedings.

5 Purposes of Processing

ace jl processes your personal data for the following purposes:

• Account creation and management: To register your account, verify your identity, maintain your player profile, and manage your account throughout its lifecycle;
• Platform service delivery: To provide access to games, process bets, calculate and credit winnings, and operate the sportsbook, live casino, slots, sabong, bingo, and e-sports sections;
• Payment processing: To process your deposits and withdrawal requests through GCash, Maya, BPI, BDO, and other accepted payment channels;
• PAGCOR regulatory compliance: To fulfil ace jl's obligations as a PAGCOR-licensed gaming operator, including player identification, reporting, and record-keeping requirements;
• Anti-money laundering (AML) compliance: To monitor transactions for unusual patterns, conduct required reporting under RA 9160, and co-operate with the Anti-Money Laundering Council (AMLC) where required;
• Fraud prevention and platform security: To detect, investigate, and prevent unauthorised access, account takeover, collusion, bonus abuse, and other fraudulent or prohibited conduct;
• Responsible gaming: To monitor gameplay patterns, enforce self-imposed limits and exclusions, and identify players who may require responsible gaming support;
• Customer support: To respond to your queries, resolve disputes, and process complaints;
• Communications: To send you transactional communications (OTPs, deposit confirmations, withdrawal receipts) and, with your consent, promotional communications about ace jl offers;
• Platform improvement: To analyse usage patterns, conduct testing, and improve the functionality, performance, and user experience of the ace jl platform.

6 Legal Bases for Processing

Under the Data Privacy Act of 2012, ace jl relies on the following legal bases to process your personal data:

7 Sharing Your Personal Data

ace jl does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• PAGCOR and regulatory authorities: ace jl discloses player data to PAGCOR, the AMLC, and other competent Philippine authorities when required by law, regulation, court order, or as a condition of our gaming licence;
• Payment processors: GCash, Maya, BPI, BDO, UnionBank, Coins.ph, and other accepted payment providers receive the minimum data necessary to process your deposit or withdrawal transaction;
• Identity verification providers: Third-party KYC and document verification service providers process your identity documents solely for the purpose of verifying your identity in compliance with PAGCOR and AMLC requirements;
• Cloud and infrastructure providers: ace jl uses cloud hosting services to operate the platform. These providers process data only on ace jl's instructions and under binding data processing agreements;
• Fraud and security providers: Third-party services that assist ace jl in detecting fraudulent activity, account compromise, and policy violations;
• Legal and professional advisors: Lawyers, auditors, and other advisors who require access to data to provide their professional services to ace jl, subject to confidentiality obligations.

All third parties to whom ace jl shares personal data are required by contract to maintain the confidentiality and security of that data and to process it only in accordance with ace jl's instructions and applicable Philippine law.

8 Data Retention

ace jl retains personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with applicable Philippine legal and regulatory requirements, and to resolve any disputes or enforce our rights.

The following retention periods apply as general guidelines:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Transaction records: Retained for a minimum of five (5) years following the date of each transaction, in compliance with AMLC record-keeping requirements;
• Gameplay records: Retained for a minimum of three (3) years following the relevant session, for audit, dispute resolution, and regulatory reporting purposes;
• Customer support records: Retained for two (2) years from the date of resolution of the relevant support interaction;
• Marketing consent records: Retained for the duration of the consent period and for three (3) years following withdrawal, to evidence compliance;
• Self-exclusion and responsible gaming records: Retained for a minimum of five (5) years to prevent re-registration during the exclusion period and to comply with PAGCOR responsible gaming requirements.

Upon expiry of the applicable retention period, ace jl will securely delete or anonymise your personal data, whichever is technically and operationally appropriate in the circumstances.

9 Security Measures

ace jl implements a comprehensive set of technical, organisational, and physical security measures designed to protect your personal data from unauthorised access, disclosure, alteration, loss, or destruction. These measures include, without limitation:

• 256-bit SSL/TLS encryption for all data in transit between your device and ace jl's servers;
• Encryption at rest for sensitive personal data stored on ace jl's infrastructure;
• Multi-factor authentication (SMS OTP) available to all players for account login, and required for all ace jl administrative systems;
• Role-based access controls limiting access to personal data to ace jl personnel who require it to perform their job functions;
• Automated intrusion detection and prevention systems monitoring for anomalous activity across the ace jl platform;
• Regular security audits and penetration testing conducted by independent security specialists;
• Incident response protocols enabling ace jl to detect, respond to, and notify affected individuals and the National Privacy Commission of personal data breaches within the timeframes prescribed by the Data Privacy Act.

10 Cookies and Tracking Technologies

10.1 What Are Cookies

Cookies are small text files stored on your device when you visit a website. ace jl uses cookies and similar tracking technologies (including local storage and session tokens) to operate the platform, maintain your authenticated session, remember your preferences, and analyse how the platform is used.

10.2 Types of Cookies Used by ace jl

• Strictly necessary cookies: Essential for the platform to function. These include session authentication tokens, security cookies, and language preference cookies. They cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences (such as game lobby sort order, display settings) to personalise your experience. Disabling these will not prevent access but may reduce convenience.
• Analytics cookies: Used to collect aggregated data about how visitors use the platform — pages visited, time spent, error logs. ace jl uses this data to improve platform performance. Analytics cookies require your consent and may be declined.
• Security cookies: Used to detect fraud, prevent unauthorised logins, and maintain session integrity. These are treated as strictly necessary and cannot be disabled.

10.3 Managing Cookies

You may control cookie settings through your browser preferences. Most modern browsers allow you to refuse some or all cookies, delete existing cookies, or be notified when cookies are set. Note that refusing strictly necessary cookies will prevent you from logging into ace jl. Analytics cookies may be declined without affecting access to any platform feature.

11 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by ace jl:

To exercise any of the above rights, please contact ace jl's Data Privacy Officer through the channels described in Section 15. ace jl will respond to data subject requests within thirty (30) calendar days. In complex cases, this period may be extended by a further thirty (30) days, with prior notice to you. Some rights may be limited where ace jl is required by law to retain the data, or where the data is necessary for the establishment, exercise, or defence of legal claims.

12 Children's Privacy and Age Restriction

The ace jl platform is strictly restricted to persons aged 21 years and above as mandated by PAGCOR regulations and Philippine law governing online gaming. ace jl does not knowingly collect, process, or retain personal data from individuals under the age of 21.

All accounts undergo age verification at registration. Where ace jl identifies or is notified that an account belongs to a person under 21, all associated data will be deleted promptly (subject to any overriding legal obligation to retain records related to the underage registration event for regulatory reporting purposes), and the account will be permanently closed.

13 International Data Transfers

ace jl operates primarily within the Philippines and processes most player data on servers located within or connected to Philippine-jurisdiction infrastructure. Where ace jl engages third-party service providers whose processing activities involve the transfer of personal data outside the Philippines — for example, cloud hosting providers with regional data centres or international fraud screening providers — ace jl ensures that such transfers are subject to appropriate safeguards as required by the Data Privacy Act and its Implementing Rules and Regulations.

Appropriate safeguards for cross-border data transfers may include binding contractual obligations consistent with the NPC's standard clauses, or transfers to countries that the NPC has recognised as providing an adequate level of data protection. ace jl does not transfer personal data internationally beyond what is operationally necessary and legally permitted.

14 Amendments to This Privacy Policy

ace jl reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, legal or regulatory requirements, or platform features. When we make material changes to this Policy, we will notify registered players by posting a prominent notice on the acejl.win platform and, where practicable, by sending a notification to the mobile number or email address registered to your account.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. You are encouraged to review this Policy periodically. Continued use of ace jl following the effective date of any amendment to this Policy constitutes acceptance of the revised terms.

If you disagree with a material change to this Policy and do not wish to continue using ace jl under the revised terms, you have the right to close your account and request deletion of your personal data subject to our legal retention obligations, as described in Section 8.

15 Contact and Complaints

15.1 Data Privacy Officer

ace jl has designated a Data Privacy Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Policy. To contact the DPO, or to submit a data subject access request, a correction request, or an erasure request, please use the following channels:

15.2 National Privacy Commission

If you are not satisfied with ace jl's response to your privacy concern, or if you believe ace jl has processed your personal data in violation of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information about how to file a complaint is available through the NPC's official channels and published guidelines.

ace jl encourages players to contact us in the first instance so that we have the opportunity to address your concern directly before any escalation to the NPC.