How dmjl Protects Your Personal Data

1 Introduction

dmjl ("we," "us," or "the Company") is committed to protecting the privacy and personal data of all players and visitors who use our online casino and sports betting platform at dmjl.net (the "Platform"). We understand that when you share your personal information with us, you are placing trust in us – and we take that responsibility very seriously.

This Privacy Policy explains in plain, straightforward English what personal data we collect, the reasons we collect it, how we store and protect it, when and with whom we may share it, and what rights you have under Philippine data privacy law. We have written this policy to be as clear and readable as possible, because we believe every Filipino player deserves to understand exactly how their information is handled – without having to wade through pages of confusing legal jargon.

This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, all of which govern your use of the dmjl Platform.

2 Scope & Data Controller

2.1 Scope

This Privacy Policy applies to all personal data collected and processed in connection with your use of the dmjl Platform, including the website at dmjl.net, any mobile-optimised interfaces, customer support communications, promotional activities, and any other services provided by dmjl to players in the Philippines.

2.2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, dmjl acts as the personal information controller in respect of the personal data collected through the Platform. All questions, requests, or concerns relating to the processing of your personal data should be directed to our Data Protection Officer (DPO) whose contact details are set out in Section 14 of this Policy.

2.3 Applicable Law

dmjl complies with the Philippine Data Privacy Act of 2012 (RA 10173), the regulations and issuances of the National Privacy Commission (NPC), and any applicable guidelines issued by PAGCOR in connection with the processing of player data. Where applicable, we also observe internationally recognised best practices for data protection and privacy.

3 Personal Data We Collect

dmjl collects personal data from you in several ways – directly when you register and interact with the Platform, automatically through your use of our website and services, and in some cases from third parties such as payment processors and identity verification providers.

3.1 Data You Provide Directly

• Registration data: Full legal name, date of birth, gender, nationality, residential address (including city – e.g., Manila, Cebu, Davao, Makati, or Quezon City), email address, and mobile number.
• Identity verification (KYC) documents: Government-issued ID (passport, driver's licence, PhilSys card, SSS ID), proof of address (utility bill, BDO or BPI bank statement), and proof of payment method ownership.
• Financial data: Deposit and withdrawal transaction details, chosen payment method (GCash, Maya, BPI, BDO, Metrobank, etc.), and transaction reference numbers. We do not store full card numbers or GCash PINs.
• Communications data: Messages and records from live chat, email support, feedback forms, and any other correspondence you send to dmjl.
• Responsible gaming data: Deposit limits, session time preferences, self-exclusion requests, and any other responsible gaming settings you configure.

3.2 Data Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and time zone.
• Usage and behavioural data: Pages visited, games played, session duration, betting history, wager amounts, game preferences, and click patterns on the Platform.
• Cookies and similar technologies: Session identifiers, preference cookies, analytics cookies, and performance tracking data. See Section 7 for full details.

3.3 Data from Third Parties

• Payment processors: Transaction confirmation data from GCash, Maya, BPI, and other payment partners to verify and reconcile your deposits and withdrawals.
• Identity verification providers: KYC verification results and watchlist screening outcomes from our third-party verification partners.
• Fraud prevention services: Risk signals and device fingerprint data from anti-fraud partners used to protect the integrity of the Platform.

4 How We Use Your Personal Data

dmjl uses your personal data only for specific, legitimate purposes that are directly connected to the operation of the Platform and delivery of our services to you. The table below summarises the key purposes:

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, dmjl processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil the contract between you and dmjl – i.e., to register your account, process transactions, and deliver gaming services.
• Legal obligation: Processing required to comply with dmjl's obligations under Philippine law, including PAGCOR regulations, AML requirements, and NPC guidelines.
• Legitimate interests: Processing carried out in pursuit of dmjl's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and interests.
• Consent: Processing carried out on the basis of your freely given, specific, and informed consent – for example, in connection with marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Sharing Your Personal Data

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

6.1 Service Providers

We engage trusted third-party service providers who assist in the operation of the Platform. These include payment processors (GCash, Maya, BPI, BDO, and others), KYC and identity verification providers, cloud hosting and infrastructure partners, customer support platform providers, and anti-fraud technology partners. All service providers are contractually bound to process your data only on our instructions and in compliance with RA 10173.

6.2 Game Providers

Certain games on the dmjl Platform are supplied by licensed third-party game providers. Where necessary for the delivery of those games (for example, in live dealer games), limited player data such as session identifiers may be shared with game providers. These providers are subject to their own licensing obligations and data protection requirements.

6.3 Regulatory Authorities

dmjl may be required by law or by a competent regulatory authority (including PAGCOR, the NPC, the Anti-Money Laundering Council, or other Philippine government agencies) to disclose certain player data. We will comply with any legally valid and binding request for disclosure, and where permitted by law, we will notify you of such a request.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of dmjl's business, player data may be transferred to the relevant successor entity, subject to that entity assuming the same data protection obligations as set out in this Policy. You will be notified of any such transfer in advance.

6.5 With Your Consent

We may share your data with third parties in any other circumstances where you have provided your explicit consent to such sharing.

7 Cookies & Tracking Technologies

dmjl uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage, and in some cases deliver relevant promotional content. A cookie is a small text file stored on your device when you visit a website.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may impair the functionality of the Platform. For detailed instructions on managing cookies in Chrome, Firefox, Safari, or other browsers, refer to your browser's help documentation.

8 Data Retention

dmjl 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 law and regulation. The following retention periods apply:

• Active account data: Retained for the duration of your account relationship with dmjl plus a minimum of five (5) years after account closure, in accordance with PAGCOR record-keeping requirements and AML regulations.
• Financial transaction records: Retained for a minimum of five (5) years following the date of the transaction, as required under Philippine AML legislation.
• KYC and identity documents: Retained for the period required by applicable regulatory obligations, typically five (5) years from account closure.
• Customer support communications: Retained for three (3) years from the date of the most recent interaction, or longer if the communication relates to an unresolved dispute or legal matter.
• Marketing preferences and consent records: Retained for the period during which you remain a registered player, and for three (3) years following account closure as evidence of consent history.
• Website analytics data: Anonymised or aggregated analytics data may be retained indefinitely for platform improvement purposes.

Upon expiry of applicable retention periods, your personal data will be securely deleted or anonymised in accordance with dmjl's data disposal procedures.

9 Security Measures

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

• Transport Layer Security (TLS): All data transmitted between your device and dmjl is encrypted using industry-standard TLS protocols, ensuring that your login credentials, financial data, and personal information cannot be intercepted in transit.
• Data encryption at rest: Sensitive personal data stored in our systems, including KYC documents and financial records, is encrypted at rest using AES-256 encryption.
• Access controls: Access to player personal data within dmjl is restricted on a strict need-to-know basis. All staff with access to personal data undergo data privacy training and are bound by confidentiality obligations.
• Multi-factor authentication: Administrative access to systems containing player data requires multi-factor authentication to prevent unauthorised access even in the event of credential compromise.
• Security monitoring: dmjl maintains continuous security monitoring of our systems and infrastructure to detect and respond to potential threats and anomalies in real time.
• Penetration testing: Our Platform undergoes regular third-party security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited.

10 Your Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by dmjl. You may exercise any of these rights at any time by contacting our Data Protection Officer as set out in Section 14.

• Right to be Informed: The right to be informed that your personal data is being collected and processed, and to be provided with the information set out in this Privacy Policy before or at the time of collection.
• Right of Access: The right to obtain confirmation of whether dmjl holds personal data about you, and to request a copy of that data in an accessible format.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or completed. You may update many of your account details directly from within your dmjl account settings.
• Right to Erasure: The right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to dmjl's legal and regulatory retention obligations.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another organisation where technically feasible.
• Right to Object: The right to object to the processing of your personal data on grounds relating to your particular situation, including the right to opt out of direct marketing communications at any time.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that dmjl has processed your personal data in a manner that infringes RA 10173.

We will respond to all valid data subject requests within fifteen (15) business days of receipt. In complex cases, we may extend this period by a further fifteen (15) business days, provided we inform you of the extension and the reasons for it.

11 Minors & Age Policy

The dmjl Platform is strictly for individuals aged 21 years or older, in accordance with Philippine gaming regulations. dmjl does not knowingly collect personal data from persons under the age of 21.

If you are the parent or guardian of a person under 21 who you believe may have provided personal data to dmjl, please contact us immediately at [email protected]. We will promptly investigate and, if confirmed, delete all personal data associated with that individual and close any account registered in their name.

We employ age verification procedures at the point of registration and may conduct additional age checks at any time. If we are unable to verify that a player is aged 21 or above, we will suspend their account and withhold any funds pending verification.

12 International Data Transfers

The dmjl Platform primarily operates within the Philippines, and we endeavour to keep your personal data within Philippine borders wherever practicable. However, some of our third-party service providers – including cloud infrastructure partners, KYC verification providers, and game software suppliers – may process your data on servers located outside the Philippines.

Where personal data is transferred outside the Philippines, dmjl ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that required under RA 10173. These safeguards may include:

• Standard contractual clauses approved by or consistent with NPC guidelines;
• Transfers to countries deemed by the NPC to provide an adequate level of data protection;
• Binding corporate rules applicable to groups of companies; or
• Your explicit consent to the transfer in specific circumstances.

You may request information about the specific safeguards in place for any international transfer of your data by contacting our Data Protection Officer.

13 Changes to This Policy

dmjl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or improvements to the Platform. The date of the most recent update will always be displayed at the top of this page.

Where we make material changes to this Policy – meaning changes that significantly affect your privacy rights or the way we process your data – we will notify registered players by email and by means of a prominent notice on the Platform at least fourteen (14) days before the changes take effect.

Your continued use of the dmjl Platform following the publication of any updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the revised Policy, you should cease using the Platform and may request account closure in accordance with our Terms & Conditions.

14 Contact & Data Protection Officer

dmjl has appointed a Data Protection Officer (DPO) as required under the Philippine Data Privacy Act of 2012. If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or want to raise a privacy concern, please contact our DPO directly:

• Email: [email protected] (Subject: "Data Privacy Request")
• Response time: We aim to acknowledge all privacy requests within 2 business days and respond fully within 15 business days.
• Live Chat: Available 24/7 through the dmjl Platform for general queries; privacy-specific requests should be directed to the email above.

If you are not satisfied with our response to a privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC handles complaints from data subjects regarding alleged violations of RA 10173.