superjl Privacy Policy

1 Introduction

superjl ("superjl," "we," "us," or "our") operates the online gaming platform accessible at superjl.org (the "Platform"). This Privacy Policy describes how superjl collects, uses, discloses, stores, and protects the personal information of individuals ("you," "your," or "Player") who register for, access, or use the superjl Platform.

This Privacy Policy applies to all personal data processed by superjl in connection with the Platform, including data collected through the website, customer support channels, and any other interaction you have with superjl. It should be read together with our Terms and Conditions, which govern your use of the Platform.

superjl acts as the Personal Information Controller in respect of the personal data it collects from players. By registering for a superjl account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2 Personal Data We Collect

superjl collects the following categories of personal data from players:

superjl does not intentionally collect sensitive personal information beyond what is necessary for identity verification and regulatory compliance. We do not collect information about your race, religion, political opinions, or health status unless you voluntarily provide such information in a support communication.

3 How We Collect Your Data

superjl collects personal data through the following means:

• Direct Collection: Information you provide when registering for an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors such as GCash and Philippine banks.
• Regulatory Sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with compliance obligations, including self-exclusion registers.

4 How We Use Your Personal Data

superjl uses the personal data it collects for the following purposes:

• Account Management: To create, maintain, and manage your superjl account, including verifying your identity and eligibility to use the Platform.
• Service Delivery: To process deposits and withdrawals, provide access to games, and deliver the core gaming services of the superjl Platform.
• Legal Compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, KYC requirements, and PAGCOR regulatory directives.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the Platform and its players.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and provide responsible gaming tools and interventions.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the superjl Platform.

5 Legal Basis for Processing

superjl processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing necessary to perform our contract with you (the Terms and Conditions), including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including AML regulations, KYC requirements, tax obligations, and PAGCOR directives.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

superjl does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other Philippine payment service providers, for the purpose of processing deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services that assist superjl in verifying player identities and complying with KYC obligations.
• Game Providers: Licensed third-party game software providers who supply the games available on the superjl Platform. These providers may receive limited technical data necessary to deliver their games.
• Fraud Prevention Partners: Anti-fraud and security service providers who assist superjl in detecting and preventing fraudulent activity.
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or regulatory directive.
• Professional Advisors: Legal counsel, auditors, and other professional advisors, subject to confidentiality obligations.

All third parties with whom superjl shares personal data are required to process that data in accordance with applicable privacy laws and superjl's data protection standards. superjl does not transfer personal data outside the Philippines except where necessary and subject to appropriate safeguards.

7 Data Retention

superjl retains personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in accordance with Philippine AML and gaming regulatory requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC Documents: Retained for a minimum of five (5) years after the end of the business relationship.
• Support Communications: Retained for three (3) years from the date of the communication, or longer if related to an ongoing dispute or legal matter.
• Marketing Consent Records: Retained for the duration of the marketing relationship and for three (3) years thereafter as evidence of consent.

When personal data is no longer required, superjl will securely delete or anonymize it in accordance with its data disposal procedures.

8 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the superjl Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments.
• 24/7 security monitoring and intrusion detection systems.
• Staff training on data protection and information security best practices.

While superjl takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, superjl will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

9 Cookies & Tracking Technologies

superjl uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that prevent fraudulent use. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how players use the Platform, helping superjl improve its services. Used only with your consent.
• Marketing Cookies: Used to deliver relevant promotional content. Used only with your explicit consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the superjl Platform. For strictly necessary cookies, no consent is required as they are essential to the service.

10 Your Privacy Rights

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

• Right to Be Informed: You have the right to be informed of how your personal data is being collected and processed, which this Privacy Policy fulfills.
• Right to Access: You have the right to request a copy of the personal data superjl holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data superjl holds about you.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to superjl's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to superjl's overriding legal obligations.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe superjl has violated your data privacy rights.

To exercise any of the above rights, please contact the superjl Data Protection Officer at the contact details provided in Section 13 of this Privacy Policy. superjl will respond to all verified requests within thirty (30) days of receipt, in accordance with the Data Privacy Act of 2012.

11 Children's Privacy

The superjl Platform is strictly intended for adults aged twenty-one (21) years and above, in accordance with Philippine gaming regulations. superjl does not knowingly collect personal data from individuals under the age of 21.

If superjl becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be handled in accordance with superjl's Terms and Conditions and applicable Philippine law.

If you are a parent or guardian and believe that your child has registered on the superjl Platform, please contact our support team immediately at [email protected] so that we can take appropriate action.

12 Changes to This Privacy Policy

superjl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, superjl will notify registered players by email or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how superjl protects your personal data.

Your continued use of the superjl Platform after the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the revised Privacy Policy, you must cease using the Platform and may request account closure by contacting our support team.

13 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or superjl's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: "Data Privacy Inquiry" or "Data Privacy Request"
• Response Time: Within 30 days of receipt of a verified request
• Live Chat: Available 24/7 via the superjl Platform for general privacy questions

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

• National Privacy Commission (NPC)
• Address: 3rd Floor, Core G, GSIS Headquarters, Financial Center, Roxas Boulevard, Pasay City, Metro Manila
• Website: privacy.gov.ph (visit directly in your browser)