JollyP Privacy Policy

1.Introduction

JollyP ("JollyP," "we," "us," or "our") operates the online gaming platform accessible at jollyp.com and through our associated mobile applications (collectively, the "Platform"). This Privacy Policy explains how JollyP collects, uses, discloses, stores, and protects the personal information of individuals who register accounts, visit the Platform, or otherwise interact with our services ("you" or "Player").

JollyP is committed to protecting the privacy and personal data of all users in accordance 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 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2.Personal Data We Collect

JollyP collects the following categories of personal data, depending on how you interact with the Platform:

2.1 Registration and Identity Data

• Full legal name
• Date of birth (for age verification — you must be 21 or older)
• Philippine mobile number
• Email address
• Username and encrypted password
• Residential address (province, city/municipality)

2.2 Identity Verification (KYC) Data

• Government-issued identification documents (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys ID)
• Proof of address documents
• Selfie or facial image for identity verification purposes
• Proof of payment method ownership

2.3 Financial and Transaction Data

• GCash or PayMaya account number (masked)
• Bank account details for BPI, BDO, or Metrobank transfers (masked)
• Deposit and withdrawal history
• Transaction amounts and timestamps

2.4 Gaming Activity Data

• Game session history, bet amounts, and outcomes
• Bonus and promotion usage records
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

2.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration and navigation patterns on the Platform
• Cookie identifiers and similar tracking data

2.6 Communications Data

• Customer support chat logs and email correspondence
• Feedback, complaints, and survey responses
• Marketing communication preferences

3.How We Collect Your Data

JollyP collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to surveys and promotions.
• Automatically: Through cookies, web beacons, and similar technologies when you browse or use the Platform. This includes technical data such as your IP address, device information, and session activity.
• From payment providers: GCash, PayMaya, BPI, BDO, and Metrobank may share transaction confirmation data with JollyP to facilitate payment processing and fraud prevention.
• From identity verification services: Third-party KYC and identity verification providers may share verification results with JollyP as part of our regulatory compliance obligations.
• From regulatory authorities: JollyP may receive information from PAGCOR or other Philippine regulatory bodies in connection with licensing, compliance, or investigation matters.

4.How We Use Your Personal Data

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

5.Legal Basis for Processing

JollyP processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to register your account, provide gaming services, and process financial transactions pursuant to our Terms and Conditions.
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving the quality of our services, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6.Sharing Your Personal Data

6.1 Third-Party Service Providers

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

6.2 Regulatory and Law Enforcement Authorities

JollyP may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), or other Philippine government authorities where required by law, court order, or regulatory directive. JollyP will not disclose more data than is strictly necessary to satisfy the applicable legal requirement.

6.3 Business Transfers

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

6.4 No Sale of Personal Data

JollyP does not sell, rent, or otherwise transfer your personal data to third parties for their own independent marketing or commercial purposes. Any sharing of data is limited to what is necessary for the purposes described in this Privacy Policy.

7.Data Retention

JollyP retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering and gaming regulatory requirements.
• Financial and transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the AMLC and BIR regulations.
• KYC documents: Retained for the duration of your account and for a minimum of five (5) years after account closure.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.
• Technical and session data: Retained for up to twelve (12) months for security and analytics purposes.

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

8.Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit the JollyP Platform. They allow the Platform to recognise your device, remember your preferences, and provide a more personalised experience. JollyP also uses similar technologies such as web beacons and local storage for comparable purposes.

8.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations.
• Analytics cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymised where possible.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats.

8.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the JollyP Platform. Instructions for managing cookies are available in the help documentation of your browser (Chrome, Firefox, Safari, Edge).

9.Data Security

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

• Transport Layer Security (TLS): All data transmitted between your device and the JollyP Platform is encrypted in transit using TLS 1.2 or higher.
• Password hashing: Account passwords are stored using industry-standard one-way cryptographic hashing algorithms. JollyP staff cannot view your password in plain text.
• Access controls: Access to personal data is restricted to authorised JollyP personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Infrastructure security: JollyP's servers and databases are hosted in secure, access-controlled data centres with physical and logical security controls.
• Fraud monitoring: Automated systems continuously monitor for suspicious account activity, unusual transaction patterns, and potential security threats.
• Regular security assessments: JollyP conducts periodic security reviews and vulnerability assessments of its systems and processes.

While JollyP takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a data breach that poses a risk to your rights, JollyP will notify you and the National Privacy Commission as required by law.

10.Your Data Rights

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

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of access: You may request a copy of the personal data JollyP holds about you, along with information about how it is being processed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data held by JollyP. You can update basic account information directly through your account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to JollyP's legal and regulatory retention obligations.
• Right to object: You may 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, subject to JollyP's overriding legal obligations.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format 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 JollyP has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 14 of this Policy. JollyP will respond to all verified data rights requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11.Children's Privacy

The JollyP Platform is strictly intended for adults aged 21 years and older. JollyP does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted during the registration process, and JollyP reserves the right to request documentary proof of age at any time.

If JollyP becomes aware that personal data has been collected from a person under the age of 21 without appropriate 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 JollyP Platform, please contact us immediately at the details provided in Section 14.

12.International Data Transfers

JollyP primarily processes and stores personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure and KYC verification providers — may process data in other countries. Where personal data is transferred outside the Philippines, JollyP ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Philippine law.

Such safeguards may include contractual data processing agreements incorporating standard data protection clauses, or transfers to countries recognised by the NPC as providing an adequate level of data protection. JollyP will not transfer your personal data to jurisdictions that do not provide adequate protections without your explicit consent or a valid legal basis.

13.Updates to This Privacy Policy

JollyP 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. The date of the most recent revision is indicated at the top of this page.

Where changes are material, JollyP will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how JollyP protects your personal information.

14.Contact Us & Data Protection Officer

JollyP has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact us through the following channels:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.