Privacy Policy — lvjl

1. Who We Are

lvjl ("lvjl," "we," "us," or "our") operates the online gaming platform accessible at lvjl.app (the "Platform"), offering casino games, slots, bingo, live dealer games, and sports betting services to players in the Philippines. lvjl is the data controller responsible for the personal data collected through the Platform.

This Privacy Policy applies to all users of the lvjl Platform, including registered players, visitors who browse the Platform without registering, and individuals who contact our customer support team. By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

If you have any questions or concerns about how lvjl handles your personal data, you may contact our Data Privacy Officer at any time. Contact details are provided in Section 12 of this Policy.

2. Personal Data We Collect

lvjl collects personal data that you provide directly to us, data generated through your use of the Platform, and data received from third-party sources where permitted by law. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., Philippine National ID, passport, driver's license).
• Contact Data: Email address, mobile number, and residential address (including city, province, and postal code).
• Account Data: Username, password (stored in encrypted form), security questions and answers, and account preferences.
• Financial Data: Payment method details (e.g., GCash account number, PayMaya account, BPI/BDO/Metrobank account details, Visa/Mastercard card details). Full card numbers are not stored by lvjl — payment processing is handled by our PCI-DSS compliant payment partners.
• KYC Documentation: Copies of government-issued identification, proof of address documents, and selfie verification images submitted during the Know Your Customer (KYC) process.
• Communications Data: Records of your communications with lvjl's customer support team, including live chat transcripts, email correspondence, and support ticket history.

2.2 Data Generated Through Platform Use

• Transaction Data: Records of all deposits, withdrawals, wagers, game results, bonus activations, and account balance history.
• Gaming Activity Data: Games played, session duration, betting patterns, win/loss history, and responsible gaming tool usage.
• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and unique device identifiers.
• Usage Data: Pages visited, features accessed, time spent on the Platform, click-through data, and navigation paths.
• Location Data: General geographic location derived from your IP address, used to verify that you are accessing the Platform from a permitted jurisdiction.

2.3 Data from Third Parties

• Payment Processors: Transaction confirmation data and fraud screening results from GCash, PayMaya, and banking partners.
• Identity Verification Providers: Results of automated identity and document verification checks conducted during KYC.
• Fraud Prevention Services: Risk scores and flagging data from third-party fraud detection services used to protect the integrity of the Platform.

3. How We Use Your Personal Data

lvjl uses the personal data we collect for the following purposes:

lvjl does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have provided explicit consent.

4. Legal Basis for Processing

lvjl processes your personal data on the following legal bases under applicable Philippine data protection law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations:

• Contractual Necessity: Processing required to perform our contract with you — including account management, payment processing, and game delivery — is carried out on the basis of contractual necessity.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC, AML obligations, and reporting requirements to regulatory authorities, is carried out on the basis of legal obligation.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and analytics is carried out on the basis of lvjl's legitimate interests, provided those interests are not overridden by your rights and interests.
• Consent: Processing for direct marketing communications and non-essential cookies is carried out on the basis of your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Cookies & Tracking Technologies

lvjl uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and deliver relevant content. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations. Disabling these may affect your experience.
• Analytics Cookies: Collect anonymized data about how players use the Platform, which pages are most visited, and where errors occur. This data helps us improve the Platform.
• Marketing Cookies: Used to deliver relevant promotional content based on your gaming activity and preferences. These are only set with your consent.

You can manage your cookie preferences through your browser settings at any time. Note that disabling certain cookies may limit the functionality of the Platform.

6. Sharing Your Personal Data

lvjl does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following circumstances:

• Payment Processors: We share financial data with GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard as necessary to process your transactions. These partners are bound by their own privacy policies and applicable data protection laws.
• Identity Verification Providers: KYC documentation is shared with accredited identity verification service providers to fulfill our regulatory obligations.
• Game Providers: Certain gaming activity data (such as player ID and session tokens) is shared with our game software providers to deliver games. These providers do not receive your full identity or financial data.
• Fraud Prevention & Security: Technical and transaction data may be shared with fraud detection services to protect the Platform and its players.
• Regulatory Authorities: lvjl may be required to disclose personal data to Philippine regulatory authorities, law enforcement agencies, or courts in response to lawful requests, court orders, or legal obligations, including AML reporting requirements.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of lvjl's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

7. Data Retention

lvjl retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. Specific retention periods include:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction.
• KYC Documentation: Retained for a minimum of five (5) years following the end of the business relationship.
• Customer Support Records: Retained for three (3) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.
• Technical and Usage Data: Retained in anonymized or aggregated form for up to two (2) years for analytics purposes.

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

8. Data Security

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

• Encryption: All data transmitted between your device and the lvjl Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including passwords and financial information, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to lvjl personnel and authorized third parties who have a legitimate need to access it. All staff with access to personal data are subject to confidentiality obligations and regular data protection training.
• PCI-DSS Compliance: Payment card data is handled in accordance with Payment Card Industry Data Security Standards (PCI-DSS). Full card numbers are never stored on lvjl's servers.
• Intrusion Detection: lvjl employs real-time monitoring, intrusion detection systems, and regular security audits to identify and respond to potential threats.
• Incident Response: In the event of a personal data breach that poses a risk to your rights and freedoms, lvjl will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

While lvjl takes all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

9. Your Privacy Rights

Under the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by lvjl:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data lvjl 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 we hold about you. You may update certain account details directly through your account settings.
• 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 lvjl'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 where you have grounds relating to your particular situation.
• 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 that data 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) of the Philippines if you believe that lvjl has processed your personal data in violation of applicable data protection law.

To exercise any of these rights, please contact lvjl's Data Privacy Officer using the contact details provided in Section 12. We will respond to all verified requests within thirty (30) days of receipt. We may need to verify your identity before processing your request.

10. Children's Privacy

The lvjl Platform is strictly intended for adults aged 21 years and above. lvjl does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you are not permitted to register for or use the Platform.

If lvjl becomes aware that personal data has been collected from a person under the age of 21 without verifiable parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact our support team immediately at [email protected].

11. Changes to This Privacy Policy

lvjl 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 we make material changes to this Policy, we will notify registered players by email and/or by posting a prominent notice on the Platform prior to the changes taking effect.

The "Last updated" date at the top of this page indicates when the Policy was most recently revised. We encourage you to review this Privacy Policy periodically to stay informed about how lvjl protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

12. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or lvjl's handling of your personal data, please contact our Data Privacy Officer through any of the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 through the lvjl Platform
• Response Time: We aim to respond to all privacy-related inquiries within two (2) business days.

For complaints that cannot be resolved directly with lvjl, you may contact the National Privacy Commission of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.