ffjl Casino — Privacy Policy

In this Privacy Policy, the following terms carry the meanings defined below:

• "ffjl" / "we" / "us" / "our" — the ffjl Casino operating entity, PAGCOR-licensed, operating the Platform at https://ffjl.asia.
• "Platform" — the ffjl Casino website, mobile interface, and all related services accessible at https://ffjl.asia.
• "Personal Data" — any information, whether recorded in material form or not, from which the identity of an individual is apparent, or can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual. This follows the definition under Section 3(g) of Republic Act 10173.
• "Sensitive Personal Information" — personal data about an individual's race, ethnic origin, marital status, age, colour, religion, philosophical or political affiliations, health, education, genetic or sexual life, proceedings for any offence committed or alleged, or government-issued IDs such as SSS, GSIS, passport, and TIN numbers.
• "Processing" — any operation or set of operations performed upon personal data, including collection, recording, organisation, storage, updating, modification, retrieval, consultation, use, consolidation, blocking, erasure, or destruction.
• "Data Subject" — you, as the individual whose personal data is being processed by ffjl.
• "NPC" — the National Privacy Commission of the Philippines, the independent body responsible for administering and implementing the Data Privacy Act of 2012.
• "PAGCOR" — the Philippine Amusement and Gaming Corporation.
• "AMLC" — the Anti-Money Laundering Council of the Philippines.
• "DPO" — ffjl's designated Data Protection Officer, as required under the Data Privacy Act and NPC Circular No. 16-01.

ffjl Casino is the Data Controller responsible for the personal data processed in connection with the Platform. As Data Controller, ffjl determines the purposes and means of processing your personal data.

ffjl holds a licence from the Philippine Amusement and Gaming Corporation (PAGCOR) to operate an online gaming platform within the Philippines. All personal data collected through the Platform is processed within the Philippines and in accordance with Philippine law.

Questions or requests regarding this Privacy Policy or our data processing activities should be directed to our Data Protection Officer using the contact details provided in Section 17 of this document.

ffjl collects the following categories of personal data, depending on the nature of your interaction with the Platform:

ffjl does not collect biometric data, racial or ethnic origin data, religious beliefs, health information, or political opinions except where expressly required by PAGCOR or AMLC under Applicable Law and only to the minimum extent necessary.

ffjl collects personal data through the following means:

• Direct collection from you: Information you provide during Account registration, KYC verification, payment processing, communications with customer support, and when completing responsible gaming settings in your Account.
• Automated collection via the Platform: Technical and usage data collected automatically when you access the Platform, including IP addresses, device identifiers, session data, browser information, and game interaction logs. This data is collected through server logs, session management systems, and first-party cookies.
• Payment processors: Transaction confirmations and reference numbers from GCash, PayMaya, BPI, BDO, Metrobank, and other integrated payment providers, for the sole purpose of verifying and reconciling your deposit and withdrawal transactions.
• Identity verification services: Where ffjl uses a third-party KYC or identity verification service provider, that provider may return verification results and flag data to ffjl as part of the identity confirmation process.
• PAGCOR and regulatory sources: ffjl may receive information about players from PAGCOR's national exclusion register or other regulatory databases as required for compliance purposes.

Under the Data Privacy Act of 2012, ffjl processes your personal data on the following legal bases, depending on the category of data and purpose of processing:

• Contractual necessity: Processing required to perform the contract between ffjl and you — specifically, to operate your Account, process deposits and withdrawals, and provide gaming services.
• Legal obligation: Processing required to comply with ffjl's obligations under Philippine law, including PAGCOR licence requirements, the Anti-Money Laundering Act (AMLA), Republic Act 9160 as amended, the Data Privacy Act, and all applicable gaming regulations.
• Legitimate interests: Processing necessary for ffjl's legitimate business interests, including fraud prevention, security monitoring, responsible gaming enforcement, and improvement of Platform services — where these interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications, optional features, and any processing not covered by the above bases, subject to your freely given, specific, informed, and unambiguous consent. You may withdraw marketing consent at any time.

Where processing is based on your consent, withdrawal of that consent will not affect the lawfulness of processing carried out prior to withdrawal, nor will it affect processing that continues on a different legal basis.

ffjl processes your personal data for the following specific, declared purposes:

• Creating, maintaining, and managing your ffjl Account
• Verifying your identity and age (21+) in compliance with PAGCOR requirements
• Processing deposits, withdrawals, and all financial transactions on the Platform
• Complying with KYC and AML obligations under the Anti-Money Laundering Act and PAGCOR regulations
• Detecting and preventing fraud, cheating, money laundering, and other prohibited conduct
• Administering responsible gaming tools and monitoring for indicators of problem gambling as required by PAGCOR
• Providing customer support and resolving complaints and disputes
• Improving the Platform's technical performance, user experience, and game offerings
• Sending you account-related communications including security alerts, transaction confirmations, and system notifications (these are service communications, not marketing)
• Sending you promotional and marketing communications, but only where you have provided explicit consent
• Maintaining regulatory records and fulfilling reporting obligations to PAGCOR and the AMLC
• Enforcing our Terms and Conditions and defending legal claims

ffjl does not sell your personal data. We share your personal data only in the following circumstances and with the following categories of recipients:

• PAGCOR: As the licensing authority for ffjl's gaming operations, PAGCOR has the right to access player data and transaction records as part of its regulatory oversight functions. ffjl is required to comply with all PAGCOR data requests.
• Anti-Money Laundering Council (AMLC): ffjl is required under the Anti-Money Laundering Act to file Covered Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) with the AMLC. These filings contain personal and transaction data as specified by AMLC reporting requirements.
• Payment service providers: GCash (Mynt), PayMaya (Maya), BPI, BDO, Metrobank, and other payment processors receive transaction data strictly necessary to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial regulations.
• KYC and identity verification providers: Third-party identity verification service providers may process your identity documents and personal data on behalf of ffjl solely for the purpose of completing regulatory KYC checks. These providers are engaged as data processors under binding data processing agreements.
• IT and infrastructure service providers: Cloud hosting, database management, and security service providers that process personal data on behalf of ffjl as data processors, under binding contracts that impose data protection obligations equivalent to those applicable to ffjl.
• Legal and professional advisers: Legal counsel, auditors, and other professional advisers who require access to personal data in the course of providing services to ffjl, bound by professional confidentiality obligations.
• Philippine courts and law enforcement: Where legally required by court order, subpoena, or other legal process under Philippine law.

ffjl uses first-party cookies and similar session tracking technologies on the Platform for the following purposes:

• Essential / functional cookies: Required for Platform operation, including maintaining your login session, remembering your account preferences, and enabling secure access. These cannot be disabled without impairing Platform functionality.
• Security cookies: Used to detect and prevent fraudulent logins, cross-site request forgery, and other security threats. These are necessary for the security of your Account.
• Analytics cookies: First-party analytics used by ffjl to understand how Players use the Platform — which game categories are most popular, which pages cause navigation difficulty, and where technical errors occur. This helps ffjl improve the Platform experience.
• Preference cookies: Cookies that remember your language preferences, display settings, and last-visited game categories to improve your experience on return visits.

ffjl does not use third-party advertising cookies or cross-site tracking technologies on the Platform. We do not participate in behavioural advertising networks or share cookie data with advertising platforms.

You can manage your cookie preferences through your browser settings. Disabling essential and security cookies will impair your ability to use the Platform, including the ffjl Login function. Disabling analytics and preference cookies will not affect your ability to use the Platform but may result in a less personalised experience.

ffjl retains personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal and regulatory retention obligations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with NPC guidelines on disposal of personal data. Where data has been shared with regulatory authorities, the retention obligations of those authorities apply independently of ffjl's own retention periods.

ffjl implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security measures include:

• SSL/TLS 256-bit encryption for all data transmitted between your device and ffjl's servers
• AES-256 encryption for personal data stored in ffjl's databases
• Role-based access controls ensuring staff can access only the data necessary for their specific job function
• OTP two-factor authentication for Player account access and for internal staff access to production systems
• Regular penetration testing and vulnerability assessments by independent security professionals
• Secure destruction of physical and electronic records containing personal data upon expiry of retention periods
• Staff privacy and data security training as part of onboarding and ongoing compliance programmes
• Incident response procedures aligned with NPC notification requirements under Circular No. 16-03

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ffjl. These rights are legally protected and ffjl will not penalise you for exercising them:

To exercise any of these rights, submit a written request to our Data Protection Officer at the contact details in Section 17. ffjl will respond within fifteen (15) days of receiving a verifiable request. We may require identity verification before processing certain requests to protect against unauthorised access to your data.

If you are not satisfied with ffjl's response to a data rights request, you have the right to file a complaint directly with the National Privacy Commission of the Philippines at the NPC's official address.

The ffjl Platform is strictly restricted to individuals aged 21 years and above in compliance with PAGCOR's Philippine gaming regulations. ffjl does not knowingly collect personal data from individuals under 21 years of age.

If you are a parent or guardian and believe your child may have registered on ffjl, please contact our Data Protection Officer immediately at [email protected]. We take age compliance extremely seriously and will act promptly on any such notification.

ffjl will send you marketing communications — including promotional offers, bonus notifications, and new game announcements — only where you have provided explicit, freely given consent during Account registration or at a subsequent point. Marketing consent is entirely optional and is separate from the essential service communications required for Account operation.

You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in your ffjl Account settings
• Clicking the unsubscribe link included in any marketing email from ffjl
• Contacting our support team at [email protected] with a written opt-out request

Withdrawal of marketing consent will be processed within five (5) business days. You will continue to receive essential service communications (account security alerts, transaction confirmations, KYC requests, and responsible gaming notifications required by PAGCOR) regardless of your marketing preference.

ffjl does not share your contact details with third-party marketers for the purpose of sending you their marketing materials.

In the event of a personal data breach affecting ffjl's systems, ffjl will follow the following procedures in compliance with NPC Circular No. 16-03 on Personal Data Breach Management:

• Immediate containment: Upon discovery of a breach, ffjl will immediately activate its incident response procedure to contain the breach and assess its scope and impact.
• NPC notification: Where the breach is likely to give rise to a real risk of serious harm to affected data subjects, ffjl will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, where feasible.
• Data subject notification: Where the breach is likely to result in a high risk to the rights of affected Players, ffjl will notify those Players directly as soon as reasonably practicable, providing information about the nature of the breach, data affected, and steps being taken.
• Remediation: Following containment, ffjl will conduct a root cause analysis and implement measures to prevent recurrence.

ffjl's primary data processing infrastructure is located within the Philippines. Where ffjl engages third-party service providers whose systems are located outside the Philippines — for example, cloud infrastructure or certain specialised software tools — any transfer of personal data to those providers is subject to ffjl's assessment that the recipient country provides an adequate level of protection, or the implementation of appropriate safeguards including contractual clauses.

In all cases, international transfers of personal data by ffjl are carried out in compliance with NPC rules on cross-border data transfers, specifically NPC Advisory No. 2017-01 and applicable sections of the Data Privacy Act's Implementing Rules and Regulations.

Players may request information about specific international data transfers affecting their personal data by contacting the DPO at [email protected].

ffjl reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR requirements. All amendments will be posted on this page with an updated effective date and version number.

Where amendments are material — for example, where we introduce a new processing purpose or a new category of data sharing — ffjl will notify registered Players by email or in-platform notification at least fourteen (14) days before the change takes effect. For non-material amendments, including minor clarifications and corrections, the updated Policy will be posted without advance notice.

Your continued use of the ffjl Platform after an amendment's effective date constitutes your acknowledgment of the revised Policy. If you object to any amendment, you may close your Account prior to the effective date. Please review this Policy periodically. The effective date and version number at the top of this page indicate when the Policy was last updated.

ffjl has designated a Data Protection Officer (DPO) in compliance with NPC Circular No. 16-01. The DPO is responsible for overseeing ffjl's compliance with the Data Privacy Act and this Privacy Policy, and is the primary contact for all data privacy matters.

To exercise your data subject rights, submit a privacy inquiry, report a suspected data breach, or raise a concern about ffjl's data processing practices, contact the DPO using the details below:

When contacting the DPO for data rights requests, please include your full name, registered Account mobile number, a description of your request, and a copy of a valid government-issued ID for identity verification. ffjl will not process data rights requests that cannot be matched to a verified Account holder.