Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") governs the collection, processing, use, storage, and protection of personal information by eljl ("we," "us," "our," "Company") through our website located at eljl.cam and all associated mobile applications, services, and gaming products (collectively, the "Platform").

By creating an account, accessing the Platform, or using any of our services, you acknowledge that you have read, understood, and consent to the data practices described in this Policy. If you do not agree with our privacy practices, you must immediately cease using the Platform and refrain from providing any personal information.

eljl operates under the authority of the Philippine Amusement and Gaming Corporation (PAGCOR) and is fully compliant with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all related issuances of the National Privacy Commission (NPC) of the Philippines.

2. Personal Data We Collect

eljl collects various categories of personal information necessary to provide gaming services, ensure regulatory compliance, prevent fraud, and improve user experience. The types of data we collect include:

2.1 Information You Provide Directly

When you register an account or use our services, you voluntarily provide the following information:

• Identity Information: Full legal name, date of birth, nationality, gender, government-issued identification numbers (passport, driver's license, national ID, SSS number)
• Contact Information: Email address, registered Philippine mobile number, residential address, postal code, city, province
• Account Credentials: Username, password, security questions and answers, two-factor authentication settings
• Financial Information: Bank account details, GCash/Maya account numbers, payment card information (processed securely by third-party payment processors), transaction history, deposit and withdrawal records
• Verification Documents: Copies of government-issued ID, proof of address (utility bills, bank statements), selfie photographs for identity verification, source of funds documentation
• Communication Data: Customer support chat logs, email correspondence, feedback and survey responses, complaints and dispute records

2.2 Information Collected Automatically

When you access or use the Platform, we automatically collect certain technical and usage information:

• Device Information: IP address, device type and model, operating system and version, browser type and version, device identifiers, screen resolution
• Usage Data: Pages visited, features used, games played, bet history, login timestamps, session duration, navigation paths, clickstream data
• Location Data: Geographic location derived from IP address to verify you are accessing the Platform from within the Philippines
• Performance Data: Application crashes, error reports, loading times, connectivity issues

2.3 Information from Third-Party Sources

We may receive personal information about you from third-party sources, including:

• Payment processors (GCash, Maya, banks) providing transaction confirmation and fraud prevention data
• Identity verification services confirming authenticity of submitted documents
• Publicly available sources and databases for fraud detection and regulatory compliance
• Marketing partners (only if you consented to data sharing with them)

3. How We Use Your Personal Data

eljl processes your personal information for specific, legitimate purposes authorized by Philippine law and necessary for providing online gaming services. We use your data for the following purposes:

3.1 Account Management and Service Provision

• Creating and maintaining your gaming account
• Processing deposits, bets, and withdrawals
• Managing your account balance and transaction history
• Providing customer support and responding to inquiries
• Enabling you to participate in games, promotions, and tournaments
• Sending essential service communications (account notifications, transaction confirmations, security alerts)

3.2 Regulatory Compliance and Legal Obligations

• Verifying your identity and age (21+ requirement) through KYC (Know Your Customer) procedures
• Complying with PAGCOR licensing requirements and regulations
• Meeting obligations under the Anti-Money Laundering Act (AMLA) and related laws
• Reporting suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Responding to lawful requests from government authorities, courts, and regulators
• Maintaining records required by law for audit and inspection purposes

3.3 Security, Fraud Prevention, and Risk Management

• Detecting and preventing fraudulent transactions and account abuse
• Identifying suspicious betting patterns and collusion
• Protecting against unauthorized access and cyber attacks
• Enforcing our Terms and Conditions and investigating violations
• Preventing money laundering, terrorism financing, and other illegal activities
• Implementing responsible gaming measures and self-exclusion programs

3.4 Platform Improvement and Analytics

• Analyzing user behavior to improve Platform functionality and user experience
• Conducting market research and developing new features
• Testing and optimizing game performance
• Generating aggregated, anonymized statistics for business intelligence

3.5 Marketing and Promotional Communications (With Your Consent)

• Sending promotional offers, bonuses, and special campaigns via email and SMS
• Personalizing gaming recommendations based on your preferences
• Inviting you to participate in surveys and feedback programs

4. Data Sharing and Disclosure

eljl does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with trusted third parties under the following circumstances:

4.1 Service Providers and Business Partners

We engage reputable third-party service providers to perform functions on our behalf, including:

• Payment processors: GCash, Maya, banks, and financial institutions processing deposits and withdrawals
• Identity verification services: Companies verifying authenticity of submitted documents
• Cloud hosting providers: Secure data storage and server infrastructure
• Customer support platforms: Live chat and ticketing systems
• Marketing and analytics tools: Email service providers and web analytics platforms (with your consent)

All third-party service providers are contractually obligated to protect your data, use it only for specified purposes, and comply with applicable privacy laws.

4.2 Legal and Regulatory Authorities

We may disclose your personal information to government agencies, regulators, and law enforcement when required by Philippine law or when necessary to:

• Comply with legal obligations, court orders, subpoenas, or regulatory requests from PAGCOR, NPC, AMLC, or other authorities
• Report suspicious transactions under anti-money laundering regulations
• Cooperate with investigations into illegal activities, fraud, or security breaches
• Enforce our Terms and Conditions and protect our legal rights

4.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this Policy.

4.4 With Your Consent

We may share your information with other third parties if you explicitly consent to such sharing, for example, when participating in joint promotions with partners.

5. Data Security Measures

eljl implements industry-standard technical, organizational, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:

5.1 Technical Safeguards

• Encryption: All data transmitted between your device and our servers is protected using TLS/SSL encryption protocols
• Secure Storage: Personal data is stored on secure servers with encryption at rest
• Firewall Protection: Network firewalls prevent unauthorized access to our systems
• Access Controls: Multi-factor authentication and role-based access restrictions limit employee access to personal data
• Regular Security Audits: Penetration testing and vulnerability assessments identify and address potential risks

5.2 Organizational Safeguards

• Employee training on data privacy and security best practices
• Confidentiality agreements with all staff and contractors
• Incident response procedures for data breaches
• Regular reviews and updates of security policies

5.3 Your Security Responsibilities

While eljl takes extensive measures to protect your data, account security also depends on your actions:

• Create strong, unique passwords and change them regularly
• Enable two-factor authentication (2FA) when available
• Never share your password or account credentials with anyone
• Log out after each session, especially on shared devices
• Immediately report suspicious activity or unauthorized access to customer support

6. Data Retention Policy

eljl retains your personal information only for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements.

6.1 Retention Periods

• Active Accounts: Personal data is retained for the duration of your active account and ongoing relationship with eljl
• Closed Accounts: After account closure, we retain transaction records, identification documents, and KYC data for a minimum of five (5) years as required by PAGCOR and anti-money laundering regulations
• Marketing Data: Contact information for marketing purposes is retained until you opt out or withdraw consent
• Legal Claims: Data relevant to legal disputes, investigations, or regulatory inquiries is retained until the matter is fully resolved and any appeal periods have expired

6.2 Data Deletion

Once retention periods expire and there is no legal or business justification for continued storage, eljl securely deletes or anonymizes your personal information to prevent future identification or recovery.

7. Your Privacy Rights Under Philippine Law

Under the Data Privacy Act of 2012, Filipino citizens and residents have the following rights regarding their personal data:

7.1 Right to Be Informed

You have the right to be informed about the collection, use, and sharing of your personal data before or at the time of collection. This Privacy Policy serves as that notification.

7.2 Right to Access

You have the right to access your personal information held by eljl and receive a copy in a structured, commonly used, and machine-readable format. You may request account data by contacting customer support.

7.3 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes. You may opt out of promotional communications at any time.

7.4 Right to Erasure or Blocking

You may request deletion or blocking of your personal data if it is no longer necessary for the purposes for which it was collected, you withdraw consent, you object to processing, or the data was unlawfully processed. Note that eljl must retain certain data to comply with legal and regulatory obligations even after account closure.

7.5 Right to Rectification

You have the right to correct inaccurate or incomplete personal information. You can update most account details directly through your account settings or by contacting customer support.

7.6 Right to Data Portability

You have the right to receive your personal data in a portable format and transmit it to another service provider, where technically feasible.

7.7 Right to File a Complaint

If you believe eljl has violated your privacy rights, you have the right to file a complaint with the National Privacy Commission of the Philippines.

7.8 Exercising Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected] with the subject line "Privacy Rights Request." We will respond to your request within fifteen (15) business days and may require identity verification to prevent unauthorized access to your data.

8. Cookies and Tracking Technologies

eljl uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze Platform usage, and deliver personalized content.

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit the Platform. They help us recognize your device, remember your preferences, and improve functionality.

8.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly, including login authentication and security features. These cannot be disabled.
• Performance Cookies: Collect anonymous data on how users interact with the Platform to improve performance and user experience.
• Functional Cookies: Remember your preferences (language, region) and personalize your experience.
• Advertising Cookies: Track your activity to deliver relevant promotional content (only with your consent).

8.3 Managing Cookie Preferences

You can control cookie settings through your browser options. Most browsers allow you to refuse or delete cookies. However, disabling essential cookies may limit Platform functionality. For advertising cookies, you may opt out through your account settings.

9. Third-Party Services and Links

The eljl Platform may contain links to third-party websites, services, or applications (such as payment processors, social media platforms, or game providers). This Privacy Policy applies only to eljl services. We are not responsible for the privacy practices of third-party services, and we encourage you to review their privacy policies before providing any personal information.

When you use third-party payment methods (GCash, Maya, bank transfers), your financial information is processed directly by those providers according to their privacy policies. eljl does not store complete payment card details on our servers.

10. Protection of Minors

The eljl Platform is intended exclusively for individuals aged 21 and above. We do not knowingly collect personal information from minors (individuals under 21 years old). By using the Platform, you represent that you meet the minimum age requirement.

If we discover that we have inadvertently collected personal information from a minor, we will immediately delete that information and permanently close the associated account. Parents and guardians who believe their child has provided personal information to eljl should contact us immediately at [email protected].

11. Changes to This Privacy Policy

eljl may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will notify you by posting the updated Policy on the Platform with a revised "Last Updated" date and, where required by law, by sending you a direct notification via email or SMS.

Your continued use of the Platform after the updated Policy becomes effective constitutes acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we protect your information.

12. Contact Information

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

• Email: [email protected] (Subject: Privacy Inquiry)
• Live Chat: Available 24/7 on the eljl website
• Data Protection Officer: For privacy rights requests or complaints, email [email protected] with subject "Data Protection Officer"

For complaints regarding alleged violations of your data privacy rights, you may also file a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission
• 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City, Metro Manila, Philippines
• Email: [email protected]
• Website: privacy.gov.ph