smjl Casino Privacy Policy

smjl Casino ("smjl," "we," "us," or "our") is the operator of the online gaming platform accessible at smjl.app. We are committed to protecting the privacy and personal data of every player, visitor, and user who interacts with our platform — whether you are browsing our site from Manila, Cebu, Davao, Quezon City, Makati, or anywhere else in the Philippines.

This Privacy Policy ("Policy") describes how smjl Casino collects, uses, stores, shares, and protects your personal information in connection with your use of the smjl platform, including all games, features, promotions, customer support interactions, and financial transactions conducted through smjl.app.

smjl Casino acts as the Personal Information Controller (PIC) as defined under the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations. This means we determine the purposes and means by which your personal data is processed.

smjl Casino collects only the personal data that is necessary to provide you with a secure, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

A. Identity & Registration Data

• Full legal name (as it appears on your government-issued Philippine ID)
• Date of birth (to verify the 21+ age requirement)
• Gender
• Nationality and country of residence
• Government-issued ID type and number (e.g., PhilSys National ID, passport, driver's license, UMID, SSS ID)

B. Contact Data

• Email address
• Philippine mobile number
• Residential address (barangay, city/municipality, province)

C. Financial & Transaction Data

• GCash account number or registered mobile number
• PayMaya account details
• Bank account details for BPI, BDO, or Metrobank transfers (account name and number only)
• Deposit and withdrawal history
• Transaction amounts in Philippine Peso (₱)
• Source of funds declarations (where required for AML compliance)

D. Gaming & Behavioural Data

• Game session history, bet amounts, win/loss records
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, self-exclusion status)
• Login timestamps and session durations

E. Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Device identifiers and fingerprints used for fraud prevention
• Cookie data and session tokens (see Section 7)

F. Communications Data

• Records of live chat conversations with smjl Casino support agents
• Email correspondence with smjl Casino
• Feedback, complaints, and dispute records

smjl Casino collects your personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated Collection: Technical and behavioural data collected automatically when you access and use the smjl platform, including through cookies, session tracking, and device recognition technology.
• Third-Party Sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank.
• Regulatory Sources: Information received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities in connection with regulatory compliance obligations.

smjl Casino does not purchase personal data from data brokers or third-party marketing companies. All data collected is directly relevant to the provision of our gaming services and compliance with applicable Philippine law.

smjl Casino uses your personal data for the following specific purposes:

Under the Philippine Data Privacy Act of 2012 (RA 10173), smjl Casino processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and smjl Casino — specifically, to provide you with access to our gaming platform, process your deposits and withdrawals, and manage your account.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160 as amended), and the Data Privacy Act (RA 10173).
• Legitimate Interests: Processing is necessary for smjl Casino's legitimate interests in fraud prevention, platform security, responsible gaming enforcement, and service improvement — provided these interests are not overridden by your rights and freedoms.
• Consent: For optional processing activities such as marketing communications and the use of non-essential cookies, smjl Casino relies on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

smjl Casino does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your personal data with the following categories of recipients only where necessary and lawful:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, and Metrobank receive the minimum financial data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are bound by applicable Philippine financial regulations.
• KYC & Identity Verification Partners: Third-party identity verification service providers who assist smjl Casino in verifying your identity and age in compliance with PAGCOR requirements.
• Fraud Prevention & AML Compliance Partners: Specialist compliance technology providers who assist smjl Casino in detecting and preventing fraud, money laundering, and other financial crimes.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory directive.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or other lawful process.
• Technology & Infrastructure Providers: Cloud hosting, data storage, and platform technology providers who process data on smjl Casino's behalf under strict data processing agreements that require them to maintain confidentiality and security standards consistent with RA 10173.

smjl Casino uses cookies and similar tracking technologies to operate the platform, enhance your experience, and fulfil our security and compliance obligations. The types of cookies used on smjl.app are as follows:

Essential cookies cannot be disabled as they are strictly necessary for the smjl platform to function securely. For optional cookies, you can manage your preferences through the cookie settings panel accessible from the smjl.app footer. Please note that disabling functional or analytics cookies may affect certain non-essential features of the platform.

smjl Casino retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your active smjl Casino account plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• KYC & Identity Verification Records: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later, as required by AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act (RA 9160 as amended by RA 10365).
• Customer Support Communications: Retained for three (3) years from the date of the interaction, or longer if the communication relates to an ongoing dispute or legal matter.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years, to demonstrate compliance with consent requirements.
• Technical & Log Data: Retained for up to twelve (12) months for security monitoring and fraud prevention purposes, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, smjl Casino will securely delete or anonymise your personal data in accordance with our internal data disposal procedures.

smjl Casino implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security framework includes:

• Encryption: All data transmitted between your device and smjl.app is encrypted using TLS 1.2 or higher. Sensitive data at rest — including financial account details and government ID information — is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within smjl Casino's systems is restricted on a strict need-to-know basis. All staff with access to personal data undergo regular data privacy training and are bound by confidentiality obligations.
• Multi-Factor Authentication: smjl Casino's internal systems require multi-factor authentication for all staff accessing player data. Players are also encouraged to enable available account security features.
• Intrusion Detection: smjl Casino's infrastructure is monitored 24/7 for suspicious activity using automated intrusion detection and prevention systems.
• Regular Security Audits: smjl Casino conducts regular internal and third-party security assessments to identify and remediate vulnerabilities in our platform and data handling practices.
• Data Breach Response: In the event of a personal data breach that poses a risk to your rights and freedoms, smjl Casino will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with RA 10173.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by smjl Casino:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, stored, and shared — which is the primary purpose of this Privacy Policy.
• Right to Access: You have the right to request a copy of the personal data smjl Casino 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 held by smjl Casino.
• 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 smjl Casino's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that smjl Casino has violated your data privacy rights.

To exercise any of these rights, please contact smjl Casino's Data Protection Officer (DPO) using the contact details provided in Section 14. We will respond to all valid data subject requests within thirty (30) days of receipt, in accordance with RA 10173.

smjl Casino's platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gaming regulations and PAGCOR requirements. smjl Casino does not knowingly collect personal data from individuals under the age of 21.

If smjl Casino becomes aware that personal data has been collected from an individual under 21 years of age, we will immediately:

• Suspend the associated account pending investigation.
• Delete all personal data associated with the underage individual from our systems.
• Return any deposited funds in accordance with applicable regulations.
• Report the incident to relevant regulatory authorities where required by law.

smjl Casino primarily stores and processes your personal data within the Philippines. However, in certain circumstances — such as the use of cloud infrastructure providers or international KYC verification services — your personal data may be transferred to and processed in countries outside the Philippines.

Where such cross-border transfers occur, smjl Casino ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission (NPC).
• Implementing contractual clauses in agreements with international service providers that require them to maintain data protection standards consistent with RA 10173.
• Conducting due diligence on all international data processors to verify their security and privacy practices before engaging their services.

smjl Casino does not transfer your personal data to jurisdictions that do not provide adequate data protection safeguards without your explicit consent or a lawful basis under RA 10173.

smjl Casino reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, we will notify registered players via:

• An email notification sent to your registered smjl Casino email address.
• A prominent notice displayed on the smjl Casino platform upon your next login.

The "Last Updated" date at the top of this page will always reflect the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how smjl Casino protects your personal data. Your continued use of the smjl platform after the effective date of any revision constitutes your acknowledgement of the updated Policy.

smjl Casino has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012 and the National Privacy Commission's guidelines. The DPO is responsible for overseeing smjl Casino's data protection compliance and serving as the primary point of contact for data privacy matters.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by smjl Casino, please contact our Data Protection Officer using the following details:

• Data Protection Officer: smjl Casino DPO
• Email: [email protected]
• Platform: smjl.app
• Response Time: Within 30 days of receipt of your request, as required by RA 10173

If you are not satisfied with smjl Casino's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the independent regulatory authority responsible for enforcing RA 10173.