Jelevo Privacy Policy

1 Introduction

Jelevo ("we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who use the Jelevo online gaming platform. This Privacy Policy describes how Jelevo collects, uses, stores, shares, and protects personal information in connection with the operation of the Platform, including the website at jelevo.net and the Jelevo mobile application (collectively, the "Platform").

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission of the Philippines ("NPC"). Jelevo is registered as a personal information controller under applicable Philippine law and takes its obligations under the DPA seriously.

This Privacy Policy should be read together with the Jelevo Terms & Conditions, which govern your use of the Platform. Capitalized terms not defined in this Privacy Policy have the meanings given to them in the Terms & Conditions.

2 Personal Data We Collect

Jelevo collects personal data that is necessary for the operation of the Platform, the provision of gaming services, the processing of financial transactions, and compliance with applicable legal and regulatory obligations. The categories of personal data we collect include:

2.1 Registration and Account Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify that you meet the 21+ age requirement);
• Philippine mobile number and email address;
• Username and encrypted password;
• Residential address in the Philippines.

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, driver's license, SSS ID, UMID, PhilSys National ID);
• Proof of address documents (e.g., utility bills, bank statements);
• Selfie or live photo for identity verification purposes;
• Proof of payment method ownership where required.

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references;
• GCash account reference numbers, PayMaya account references, and bank account details (BDO, BPI, Metrobank) used for transactions;
• Account balance history and gaming transaction records.

2.4 Gaming Activity Data

• Game session logs, including games played, bet amounts, outcomes, and session durations;
• Responsible gaming tool settings, including deposit limits, session reminders, and self-exclusion status;
• Bonus and promotion participation records.

2.5 Technical and Device Data

• IP address and approximate geolocation data;
• Device type, operating system, and browser information;
• Session identifiers and authentication tokens;
• Log data, including access times, pages visited, and error reports.

2.6 Communications Data

• Records of communications between you and Jelevo customer support, including chat transcripts and email correspondence;
• Feedback, complaints, and dispute records.

3 How We Collect Your Data

Jelevo collects personal data through the following means:

• Directly from you: when you register for a Jelevo account, complete identity verification, make deposits or withdrawals, contact customer support, or update your account settings;
• Automatically: through cookies, web beacons, and similar tracking technologies when you access and use the Platform (see Section 7 for details on our cookie practices);
• From third-party service providers: including payment processors (GCash, PayMaya, BDO, BPI, Metrobank), identity verification service providers, and fraud detection services, where such providers share data with Jelevo in connection with the services they provide to us;
• From regulatory and law enforcement authorities: where Jelevo is required to receive or process data in connection with legal or regulatory obligations.

4 How We Use Your Personal Data

Jelevo uses the personal data it collects for the following purposes:

5 Legal Basis for Processing

Jelevo processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between you and Jelevo, including operating your account, processing transactions, and providing gaming services;
• Legal obligation: Processing is required to comply with applicable laws and regulations, including PAGCOR licensing requirements, anti-money laundering obligations, and age verification requirements;
• Legitimate interests: Processing is necessary for Jelevo's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and improving the Platform, provided those interests are not overridden by your rights and interests;
• Consent: Where Jelevo relies on your consent as the legal basis for processing — for example, for sending marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Sharing Your Personal Data

6.1 Service Providers

Jelevo may share your personal data with carefully selected third-party service providers who assist in the operation of the Platform. These include payment processors (GCash, PayMaya, BDO, BPI, Metrobank), identity verification providers, fraud detection services, cloud hosting providers, and customer support platform providers. All service providers are contractually required to process your data only on Jelevo's instructions and to maintain appropriate security measures.

6.2 Regulatory and Law Enforcement Authorities

Jelevo may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, and other government authorities where required by applicable Philippine law, court order, or regulatory directive. Jelevo will notify you of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of Jelevo's business, your personal data may be transferred to the acquiring entity as part of that transaction. Jelevo will notify you of any such transfer and ensure that the acquiring entity is bound by privacy obligations no less protective than those set out in this Privacy Policy.

6.4 No Sale of Personal Data

Jelevo does not sell, rent, or otherwise transfer your personal data to unaffiliated third parties for their own marketing or commercial purposes. Your data is not a product at Jelevo.

7 Cookies and Tracking Technologies

The Jelevo Platform uses cookies and similar tracking technologies to operate core platform functions, maintain your login session, detect fraud, and analyze how players use the Platform. The types of cookies used by Jelevo include:

• Strictly necessary cookies: Required for the Platform to function. These include session cookies that keep you logged in and security cookies that help detect fraudulent activity. These cannot be disabled without affecting Platform functionality;
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations;
• Analytics cookies: Used to collect aggregated, anonymized data about how players navigate and use the Platform, helping Jelevo improve the user experience;
• Marketing cookies: Used only with your consent to deliver relevant promotional content about Jelevo games and offers.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Jelevo Platform. For more information on managing cookies in your browser, refer to your browser's help documentation.

8 Data Retention

Jelevo retains your personal data for as long as your account remains active and for such additional periods as are required by applicable law and regulatory obligations. The following retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, as required by anti-money laundering regulations applicable to online gaming operators in the Philippines;
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Gaming activity logs: Retained for a minimum of three (3) years from the date of each session;
• Customer support communications: Retained for three (3) years from the date of the last communication;
• Marketing consent records: Retained for the duration of your account and for one (1) year following account closure or withdrawal of consent.

Upon expiry of the applicable retention period, Jelevo will securely delete or anonymize your personal data in accordance with its data disposal procedures. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for statistical and analytical purposes.

9 Data Security

Jelevo implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• AES-256 encryption for all personal data stored at rest on Jelevo servers;
• TLS 1.2 or higher encryption for all data transmitted between your device and the Platform;
• Multi-factor authentication options for player accounts;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing of Platform infrastructure;
• Intrusion detection and prevention systems monitoring Platform traffic in real time;
• Secure data backup procedures with encrypted off-site storage.

While Jelevo takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Jelevo will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

10 Your Data Privacy Rights

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 Jelevo:

• Right to be informed: You have the right to be informed about how Jelevo collects and processes your personal data, as set out in this Privacy Policy;
• Right of access: You have the right to request a copy of the personal data that Jelevo 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 that Jelevo holds about you;
• 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 Jelevo's legal and regulatory retention obligations;
• Right to object: You have the right to object to the processing of your personal data where Jelevo relies on legitimate interests as the legal basis for processing;
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to withdraw consent: Where Jelevo processes your data on the basis of your consent, you have the right to withdraw that consent at any time;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that Jelevo has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of these rights, please contact the Jelevo Data Protection Officer using the contact details provided in Section 13 of this Privacy Policy. Jelevo will respond to all data subject requests within thirty (30) days of receipt, or within such extended period as may be permitted under applicable law.

11 Children's Privacy and the 21+ Requirement

The Jelevo Platform is strictly intended for individuals who are at least twenty-one (21) years of age. Jelevo does not knowingly collect personal data from individuals under the age of 21. The 21+ age requirement is enforced through mandatory age verification during the registration process and through identity verification (KYC) procedures prior to the processing of any real-money transactions.

If Jelevo becomes aware that it has inadvertently collected personal data from an individual under the age of 21, it will take immediate steps to delete that data and close the associated account. If you believe that Jelevo may have collected personal data from a minor, please contact the Jelevo Data Protection Officer immediately using the contact details in Section 13.

12 Changes to This Privacy Policy

Jelevo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made to this Privacy Policy, Jelevo will notify registered players by email and by posting a prominent notice on the Platform at least seven (7) days before the changes take effect.

The date of the most recent revision to this Privacy Policy is indicated at the top of this page. Your continued use of the Jelevo Platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the revised Privacy Policy, you should cease using the Platform and may request closure of your account in accordance with the procedures described in the Jelevo Terms & Conditions.

13 Contact and Data Protection Officer

Jelevo has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Jelevo, please contact our DPO using the details below.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. Information about the NPC and how to file a complaint is available through official Philippine government channels.