jdprime22 Privacy Policy

1.1 This Privacy Policy ("Policy") describes how jdprime22 ("we," "us," or "the Company") collects, uses, stores, discloses, and protects the personal information of individuals ("Users," "you," or "Players") who access or use the jdprime22 Platform available at jdprime22.app.

1.2 This Policy applies to all personal information collected by jdprime22 through: the jdprime22 website and mobile-responsive interface; the account registration and KYC verification process; payment processing and transaction activities; live chat, email, and other support interactions; and any promotional or marketing activities in which you voluntarily participate.

1.3 By registering an account on jdprime22 or using our Services, you acknowledge that you have read, understood, and agreed to the collection and use of your personal information as described in this Policy. If you do not agree with any part of this Policy, please do not register an account or use the Services.

1.4 This Policy should be read together with the jdprime22 Terms & Conditions, which govern the overall use of the Platform. In the event of a conflict between this Policy and the Terms & Conditions on a privacy matter, this Policy shall prevail.

2.1 For the purposes of the Data Privacy Act of 2012 and its IRR, jdprime22 is the Personal Information Controller (PIC) in respect of personal data collected from registered Users through the jdprime22 Platform.

2.2 As a Personal Information Controller, jdprime22 determines the purposes and means of processing personal data in connection with the operation of the Platform and the provision of gaming, payment, and support services to Filipino players.

2.3 jdprime22 operates under a PAGCOR license. As a PAGCOR-regulated entity, jdprime22 is subject to regulatory data obligations imposed by PAGCOR, including anti-money laundering (AML) reporting obligations under the Anti-Money Laundering Act (AMLA) and its amendments.

2.4 Contact details for our Data Protection Officer are provided in Section 15 of this Policy.

3.1 jdprime22 collects personal data in the following categories, depending on how you interact with the Platform:

• Full legal name (as appearing on a government-issued Philippine ID)
• Date of birth (for age verification — you must be 21 or older)
• Email address
• Philippine mobile number
• Password (stored in hashed, irreversible form — never in plain text)

• Scanned copy or photograph of a valid Philippine government-issued ID (PhilHealth, SSS, UMID, Driver's License, or Passport)
• Selfie photograph for facial match verification
• Residential address in the Philippines
• Proof of address document where required for enhanced due diligence

• GCash or Maya account number (mobile number) associated with deposits and withdrawals
• Bank account name and number for bank transfer transactions (BPI, BDO, UnionBank)
• Transaction records: deposit amounts, withdrawal amounts, dates, and reference numbers
• Wallet balance history and bonus credit activity

• Game session logs: games played, bets placed, outcomes, session duration
• Sports betting selections and bet history
• Bonus and promotion participation records
• Responsible gaming tool settings (deposit limits, self-exclusion status)

• IP address at time of login and during sessions
• Device type, operating system, and browser type
• Cookie identifiers and session tokens
• Geolocation data (at the country/region level, for access control purposes)

• Live chat transcripts
• Email correspondence with jdprime22 support
• Feedback, complaint, and dispute records

4.1 jdprime22 uses your personal data for the following purposes:

4.2 jdprime22 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review. Where automated processes are used in fraud screening, a human compliance officer reviews all flagged accounts before any action is taken.

5.1 Under the Data Privacy Act of 2012, jdprime22 processes personal data under the following legal criteria:

• Consent: Where you have provided clear consent to a specific processing activity — such as opting into marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contract Performance: Processing necessary to register your account, provide gaming services, process deposits and withdrawals, and operate your account in accordance with the jdprime22 Terms & Conditions.
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (Republic Act No. 9160 as amended), and the Data Privacy Act of 2012.
• Legitimate Interest: Processing necessary for jdprime22's legitimate business interests — including fraud prevention, platform security, responsible gaming monitoring, and service improvement — where these interests are not overridden by your rights and freedoms.

6.1 jdprime22 does not sell your personal data to any third party. We share personal data only in the following circumstances and with the following categories of recipients:

• Payment Service Providers: GCash (Mynt — Globe Fintech Innovations, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, and other payment processors — to facilitate deposits and withdrawals. These providers receive only the data necessary to process specific transactions.
• KYC and Identity Verification Providers: Third-party identity verification platforms used to process government ID submissions and facial match checks. These providers process data solely on jdprime22's instructions and are contractually bound to data security standards.
• Game Content Providers: Certified gaming software providers (e.g., Pragmatic Play, PG Soft, Habanero) receive session tokens and game outcome data necessary to deliver game content. These providers do not receive personally identifiable registration or financial data.
• PAGCOR: As jdprime22's licensing regulator, PAGCOR may request access to account, transaction, or gaming activity records as part of its regulatory oversight functions. jdprime22 is legally obligated to comply with such requests.
• Anti-Money Laundering Council (AMLC): jdprime22 reports covered and suspicious transactions to the AMLC as required under the Anti-Money Laundering Act of the Philippines.
• Law Enforcement: Philippine law enforcement authorities, where jdprime22 receives a lawful order, warrant, or directive requiring disclosure of personal data.
• Legal and Professional Advisors: Lawyers, auditors, and compliance consultants engaged by jdprime22, subject to confidentiality obligations.

6.2 Where jdprime22 engages third-party Personal Information Processors (PIPs), it does so through written agreements that require PIPs to implement adequate security measures and process personal data only for the specified purpose.

7.1 jdprime22 uses cookies and similar tracking technologies on the Platform to operate core functionality, maintain security, and improve the user experience. Cookies are small text files stored on your device by your browser.

7.2 Types of cookies used by jdprime22:

• Strictly Necessary Cookies: Required for the Platform to function — for example, session management, login state, and security tokens. These cannot be disabled without breaking core functionality.
• Functional Cookies: Store your preferences such as language settings, last-played games, and display options. These improve your experience but are not required for basic Platform operation.
• Analytical Cookies: Collect anonymized or aggregated data about how Players use the Platform — pages visited, session duration, features used. This data is used to improve the Platform and is not linked to individual identities.
• Security Cookies: Used to detect and prevent fraudulent login attempts, session hijacking, and other security threats.

7.3 jdprime22 does not use third-party advertising or behavioral tracking cookies. We do not share cookie data with advertising networks.

7.4 Most browsers allow you to control or disable cookies through their settings. Note that disabling strictly necessary cookies will affect your ability to log in and use the Platform properly. You can clear cookies at any time by clearing your browser data.

8.1 jdprime22 implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and jdprime22 servers is encrypted using Transport Layer Security (TLS). This is the same encryption standard used by Philippine banks for online banking.
• Encrypted Password Storage: Passwords are never stored in plain text. They are processed using a one-way cryptographic hash with salting, making them irretrievable even in the event of a data breach.
• Two-Factor Authentication (2FA): Available and strongly recommended for all jdprime22 accounts. OTP codes sent to registered Philippine mobile numbers add a second layer of protection beyond your password.
• Role-Based Access Controls: jdprime22 staff access to personal data is restricted based on job function and the principle of least privilege. Customer support agents see only the data necessary to resolve the specific issue at hand.
• Intrusion Detection and Monitoring: Server infrastructure is monitored 24/7 for unauthorized access attempts, anomalous activity, and potential security threats.
• Regular Security Audits: jdprime22 conducts periodic security reviews of its infrastructure, codebase, and third-party integrations.

8.2 Despite these measures, no digital system can provide an absolute guarantee against all possible security threats. In the event of a personal data breach that is likely to result in harm to affected individuals, jdprime22 will notify the National Privacy Commission (NPC) within 72 hours of discovery, and affected Users within a reasonable period thereafter, in accordance with NPC Circular 16-03.

9.1 jdprime22 retains personal data for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by applicable Philippine law.

9.2 The following retention guidelines apply:

• Active account data: Retained for the duration of your account and for five (5) years following permanent account closure — as required under PAGCOR regulations and the Anti-Money Laundering Act.
• KYC identity documents: Retained for a minimum of five (5) years from the date of verification, or longer if required by PAGCOR or AMLC regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AML record-keeping obligations.
• Gaming activity logs: Retained for three (3) years from the date of each game session for operational and dispute resolution purposes.
• Support communications: Retained for two (2) years from the date of the interaction unless the matter relates to an ongoing dispute, complaint, or regulatory inquiry.
• Marketing consent records: Retained for the duration of your consent plus two (2) years following withdrawal of consent.

9.3 Upon expiry of the applicable retention period, jdprime22 will securely delete or anonymize your personal data. Anonymized data (from which you cannot be identified) may be retained indefinitely for statistical and analytical purposes.

10.1 Under the Data Privacy Act of 2012, as a data subject you have the following rights with respect to your personal information held by jdprime22:

10.2 To exercise any of the rights listed above, contact jdprime22's Data Protection Officer at the details provided in Section 15. jdprime22 will respond to data rights requests within thirty (30) calendar days. Where a request is complex or high in volume, we may extend this period by a further thirty (30) days, with notification.

10.3 Where jdprime22 is legally required to retain certain data (e.g., by PAGCOR or AMLC mandate), a request for erasure may be partially declined for the duration of the applicable legal retention obligation. We will always explain the specific legal basis for any refusal.

11.1 During registration, jdprime22 requires each User to declare their date of birth and, prior to first withdrawal, to submit a valid Philippine government-issued ID confirming their age. Any account found to be held by a person under 21 will be immediately suspended and the matter reported to PAGCOR.

11.2 If you are a parent or guardian and believe that a minor has accessed jdprime22 using your account or their own account, please contact our support team immediately via the details in Section 15. We will investigate promptly and take appropriate action, including account suspension and deletion of any data collected from the minor.

12.1 jdprime22's primary data infrastructure is based in the Philippines. Some of our third-party service providers — particularly game content providers and server infrastructure partners — may be located in other countries, including jurisdictions in Southeast Asia or internationally.

12.2 Where personal data is transferred outside the Philippines, jdprime22 ensures that such transfers are made only to countries or recipients that provide an adequate level of data protection, or subject to contractual safeguards (such as Standard Contractual Clauses or equivalent) that are consistent with the requirements of the Data Privacy Act of 2012 and applicable NPC regulations.

12.3 Financial transaction data processed through GCash and Maya remains within their respective Philippine infrastructure. Bank transfer data processed through BPI, BDO, or other Philippine banks is governed by those institutions' own privacy and data localization policies.

13.1 The jdprime22 Platform does not contain links to external third-party websites as part of its standard navigation. Where jdprime22 does provide any contextual reference to third-party services (such as GCash or Maya for payment purposes), such references are purely informational.

13.2 jdprime22 has no control over and assumes no responsibility for the privacy practices, content, or data handling of any third-party services. Your interactions with third-party payment providers such as GCash, Maya, BPI, or BDO are governed by those providers' own privacy policies and terms, which you should review independently.

14.1 jdprime22 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements from PAGCOR, the NPC, or the AMLC. When we make changes, we will update the "Last Updated" date at the top of this Policy.

14.2 For material changes to this Policy — meaning changes that significantly affect how we use your personal data or the rights available to you — jdprime22 will provide advance notice via email to your registered address or via a prominent notice on the Platform before the changes take effect.

14.3 Your continued use of the jdprime22 Platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the revised Policy, you may request account closure as provided in the Terms & Conditions.

15.1 jdprime22 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy.

15.2 To exercise your data rights, submit a privacy concern, report a potential data breach, or ask any question about how jdprime22 handles your personal information, you may contact the DPO through:

• Email: [email protected] (mark your subject line: "Privacy / DPO Request") — plain text, not a clickable link
• Live Chat: Available in-Platform at jdprime22.app — click the chat icon to reach the support team, who will escalate privacy matters to the DPO

15.3 jdprime22 will acknowledge receipt of your privacy request within 3 business days and provide a substantive response within 30 calendar days, extendable to 60 days for complex requests with notification.

15.4 If you are not satisfied with jdprime22's handling of your personal data or our response to a data rights request, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines, the independent regulatory authority responsible for data privacy enforcement in the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.