Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by no2jl ("no2jl," "we," "us," or "our") and applies to all personal data collected, processed, and stored in connection with your use of the no2jl online gaming platform, including our website, mobile interface, and all related services (collectively, the "Platform").

no2jl is committed to protecting the privacy and security of your personal information. This Policy is designed to comply with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC).

By registering an account or using the no2jl 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, please discontinue use of the no2jl Platform.

This Policy should be read together with no2jl's Terms & Conditions and Responsible Gaming Policy.

2. Information We Collect

no2jl collects personal data that is necessary to provide our services, comply with legal obligations, and maintain the security and integrity of the Platform. The categories of personal data we collect include:

2.1 Information You Provide Directly

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification details (e.g., Philippine National ID, passport, driver's license).
• Contact Data: Email address, Philippine mobile number, and residential address.
• Account Data: Username, password (stored in encrypted form), account preferences, and communication settings.
• Financial Data: Payment method details (e.g., GCash account number, PayMaya account, BPI/BDO/Metrobank account details), transaction history, deposit and withdrawal records.
• Verification Data: Copies of government-issued identification documents and proof of address submitted for Know Your Customer (KYC) verification.

2.2 Information Collected Automatically

• Technical Data: IP address, device type, operating system, browser type and version, and unique device identifiers.
• Usage Data: Pages visited, games played, session duration, betting history, and interaction logs.
• Location Data: General geographic location derived from your IP address, used to verify eligibility and comply with jurisdictional restrictions.
• Cookie Data: Information collected through cookies and similar tracking technologies, as described in Section 8 of this Policy.

2.3 Information from Third Parties

• Identity verification data from third-party KYC service providers.
• Fraud prevention and AML screening data from authorized compliance partners.
• Payment confirmation data from GCash, PayMaya, and banking partners.

3. How We Use Your Information

no2jl processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your no2jl account, including identity verification and age verification (21+ requirement).
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver customer support.
• Legal Compliance: To comply with PAGCOR regulations, anti-money laundering (AML) obligations under Republic Act No. 9160 (as amended), and other applicable Philippine laws.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized access, and other security threats.
• Responsible Gaming: To monitor gaming behavior, enforce self-exclusion requests, and implement responsible gaming tools.
• Communications: To send transactional notifications (e.g., deposit confirmations, withdrawal updates) and, with your consent, promotional communications about no2jl offers and promotions.
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the no2jl Platform.
• Dispute Resolution: To investigate and resolve complaints, disputes, and legal claims.

4. Legal Basis for Processing

no2jl processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing is necessary to perform our obligations under the no2jl Terms & Conditions, including account management and service delivery.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including PAGCOR licensing requirements and AML obligations.
• Legitimate Interests: Processing is necessary for no2jl's legitimate interests in fraud prevention, platform security, and service improvement, provided such interests are not overridden by your rights.
• Consent: For marketing communications and non-essential cookies, processing is based on your explicit consent, which you may withdraw at any time.

5. Disclosure of Your Information

no2jl does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may disclose your personal data to the following categories of recipients:

• Service Providers: Third-party vendors who assist in delivering our services, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC verification providers, IT infrastructure providers, and customer support platforms. These providers are contractually bound to process your data only as instructed by no2jl and in accordance with applicable privacy law.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a valid legal order, warrant, or subpoena.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of no2jl's assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

6. Data Retention

no2jl retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations.

• Account data and transaction records are retained for a minimum of five (5) years following account closure, as required by Philippine AML regulations.
• KYC verification documents are retained for the duration of your account and for five (5) years thereafter.
• Marketing consent records are retained for the duration of your consent and for three (3) years following withdrawal of consent.
• Technical and usage logs are retained for up to twelve (12) months for security and platform improvement purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with no2jl's data disposal procedures.

7. Data Security

no2jl implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the no2jl Platform.
• Encryption of sensitive data at rest, including passwords and financial information.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Multi-factor authentication options for user accounts.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, no2jl will notify the National Privacy Commission and affected users in accordance with the requirements of the Philippine Data Privacy Act.

8. Cookies and Tracking Technologies

no2jl uses cookies and similar tracking technologies to enhance your experience on the Platform. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the operation of the Platform, including session management and security features. These cannot be disabled.
• Functional Cookies: Used to remember your preferences and settings, such as language and display options.
• Analytics Cookies: Used to collect aggregated, anonymized data about how users interact with the Platform, helping us improve performance and usability.
• Marketing Cookies: Used, with your consent, to deliver relevant promotional content. You may opt out of marketing cookies at any time.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the no2jl Platform.

9. Your Rights Under Philippine Law

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by no2jl:

• Right to be Informed: The right to be informed of how your personal data is collected, processed, and used.
• Right of Access: The right to request a copy of the personal data no2jl holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to no2jl's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact no2jl's Data Privacy Officer at the contact details provided in Section 13 of this Policy. no2jl will respond to all verified requests within thirty (30) days.

10. Children's Privacy

The no2jl Platform is strictly intended for individuals who are at least 21 years of age, as required by PAGCOR regulations governing online gaming in the Philippines. no2jl does not knowingly collect personal data from individuals under the age of 21.

If no2jl becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete such data and close the associated account. If you believe a minor has registered on the no2jl Platform, please contact us immediately at the details provided in Section 13.

11. International Data Transfers

no2jl primarily processes personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed by service providers located outside the Philippines, including providers of cloud infrastructure, KYC verification, and fraud prevention services.

Where personal data is transferred outside the Philippines, no2jl ensures that appropriate safeguards are in place to protect your data, including contractual clauses that impose data protection obligations equivalent to those required under Philippine law. Such transfers are conducted in compliance with the Philippine Data Privacy Act and applicable NPC issuances.

12. Changes to This Privacy Policy

no2jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. Material changes will be communicated to registered users via email or a prominent notice on the no2jl Platform prior to the effective date of the change.

Your continued use of the no2jl Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how no2jl protects your personal data.

13. Contact and Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or no2jl's data processing practices, please contact our Data Privacy Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the no2jl Platform

no2jl will acknowledge receipt of your request within five (5) business days and provide a substantive response within thirty (30) days. For complaints that cannot be resolved directly with no2jl, you may contact the National Privacy Commission of the Philippines.