vpjl Privacy Policy — How We Handle Your Personal Data

This Privacy Policy is issued by vpjl and applies to all personal data collected through the vpjl online gaming platform at vpjl.club, including any associated mobile browser interfaces, player account systems, customer support channels, and promotional communications.

vpjl is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines, in accordance with applicable data protection legislation, including the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its implementing rules and regulations.

This Policy should be read together with the vpjl Terms & Conditions, which govern your use of the platform. By registering an account or using any vpjl service, you acknowledge that you have read and understood this Privacy Policy.

For the purposes of applicable data protection law, vpjl is the data controller responsible for the personal data collected through the vpjl platform. As data controller, vpjl determines the purposes and means of processing your personal data.

vpjl is responsible for ensuring that all personal data processing activities conducted through the platform comply with applicable data protection obligations. Where vpjl engages third-party service providers to process data on its behalf, those providers act as data processors under a contractual obligation to vpjl and may not use your data for any purpose outside of that contractual relationship.

For data protection enquiries, players may contact vpjl using the contact details set out in Section 15 of this Policy.

vpjl collects personal data across several categories, depending on the nature of your interaction with the platform. The categories and specific data points collected are set out below.

vpjl does not knowingly collect sensitive personal data beyond what is required for KYC and responsible gaming purposes. Where sensitive data is collected (for example, a government-issued ID photograph), it is handled under enhanced security controls and retained only for as long as required by applicable law.

vpjl collects personal data through the following means:

• Direct provision: Data you enter into the vpjl platform directly, including registration forms, KYC document uploads, cashier screens, and support contact forms;
• Automated collection: Technical and usage data collected automatically when you access the vpjl platform, through server logs, session tracking, and cookies (see Section 8);
• Third-party payment providers: Confirmation data returned by GCash, Maya, BPI, BDO, Metrobank, InstaPay, or PESONet when you initiate a deposit or withdrawal through your vpjl account;
• Identity verification services: Where vpjl uses a third-party KYC provider to verify your identity document, that provider may return verification status and document data to vpjl;
• Support interactions: Data you provide when contacting vpjl through live chat, email, or any other support channel.

vpjl does not purchase personal data from data brokers or other third-party list providers.

Every processing activity conducted by vpjl is grounded in a lawful basis under applicable data protection law. The primary legal bases vpjl relies on are as follows:

• Contractual necessity: Processing required to register your account, accept deposits, settle withdrawals, deliver game results, and fulfil all other obligations under the vpjl Terms & Conditions. Without this processing, vpjl cannot provide the service;
• Legal obligation: Processing required to comply with anti-money laundering obligations, age verification requirements, identity verification under KYC regulations, and record-keeping obligations applicable to licensed gaming operators;
• Legitimate interests: Processing undertaken in vpjl's legitimate interests, such as fraud detection and prevention, platform security, responsible gaming monitoring, and improving the player experience — provided those interests are not overridden by your privacy rights;
• Consent: Processing based on your explicit consent, such as optional marketing communications. Where consent is the legal basis, you may withdraw it at any time without affecting the lawfulness of prior processing.

vpjl uses the personal data it collects for the following specific purposes:

• Account management: Creating, verifying, and maintaining your vpjl player account;
• Age and identity verification: Confirming that you meet the minimum age requirement of 21 years and that the details you have provided are accurate and genuine;
• Transaction processing: Processing deposits via GCash, Maya, or bank transfer and executing withdrawal requests to your designated payment method;
• Game delivery: Providing access to the vpjl game library, recording game outcomes, and maintaining your game history and wallet balance;
• Fraud prevention and security: Detecting and investigating suspicious account activity, unauthorised access attempts, and potential abuse of the platform or bonus system;
• Regulatory compliance: Meeting anti-money laundering, identity verification, and reporting obligations under applicable law;
• Responsible gaming: Monitoring player activity for indicators of problem gambling and administering responsible gaming tools including deposit limits, cool-off periods, and self-exclusion;
• Customer support: Responding to your queries, complaints, and dispute submissions;
• Platform improvement: Analysing aggregated, anonymised usage data to improve platform performance, game selection, and user experience;
• Marketing (with consent only): Sending promotional offers, reload bonuses, and news about vpjl where you have opted in to receive such communications.

vpjl does not sell, rent, or license your personal data to any third party for their own commercial or marketing purposes. Your data is shared only in the following circumstances and only to the extent necessary:

• Payment service providers: GCash, Maya, BPI, BDO, Metrobank, and other payment processors receive the minimum data required to process your deposit or withdrawal transaction;
• KYC and identity verification providers: Third-party identity verification services receive your KYC documents for the purpose of confirming your identity and age;
• Game software providers: Game providers who power titles in the vpjl library may receive anonymised session identifiers for game integrity purposes. They do not receive your full identity or financial data;
• Fraud prevention and security services: Specialised fraud detection providers may receive technical and behavioural data to help vpjl identify and prevent fraudulent activity;
• Legal and regulatory authorities: vpjl will disclose personal data to law enforcement agencies, regulators, or government bodies where required to do so by applicable law, court order, or regulatory instruction;
• Professional advisers: Legal, financial, or compliance advisers engaged by vpjl may access personal data where strictly necessary for the provision of their professional services, subject to obligations of confidentiality.

All third parties with whom vpjl shares personal data are subject to contractual obligations requiring them to handle your data securely and in accordance with applicable data protection law. They are not permitted to use your data for any purpose beyond the specific service they provide to vpjl.

vpjl uses cookies and similar tracking technologies on the platform. A cookie is a small text file stored on your device by your browser when you visit a website. Cookies allow vpjl to recognise your browser, maintain your session, and improve your experience.

The types of cookies vpjl uses are as follows:

• Strictly necessary cookies: Required for the platform to function. These include session cookies that keep you logged in during your visit and security cookies used to detect and prevent fraud. These cookies cannot be disabled without affecting platform functionality;
• Functional cookies: Remember your preferences, such as your preferred game lobby view or language settings, to improve your experience across sessions;
• Analytical cookies: Collect anonymised data about how players use the vpjl platform — which pages are visited most frequently, how long sessions last, and where players encounter issues. This data is used to improve the platform and is not linked to individual player identities;
• Marketing cookies: Where you have consented to marketing communications, these cookies help vpjl deliver relevant promotional content and measure the effectiveness of promotional campaigns.

You may control cookie settings through your browser's privacy settings. Disabling strictly necessary cookies may affect your ability to use certain platform features. You may also withdraw consent for non-essential cookies at any time through your account preferences.

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

At the end of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

vpjl implements a range of technical and organisational security measures to protect your personal data from unauthorised access, loss, alteration, disclosure, or destruction. These measures include:

• Encryption in transit: All data transmitted between your browser and vpjl servers is encrypted using TLS/SSL (256-bit) technology. The padlock icon in your browser confirms an encrypted connection;
• Encryption at rest: Sensitive personal data stored on vpjl servers, including KYC documents and financial data, is encrypted at rest;
• Access controls: Access to personal data within vpjl is restricted on a need-to-know basis. Staff who can access player data are subject to strict confidentiality obligations and undergo regular data protection training;
• Two-factor authentication: vpjl supports two-factor authentication (2FA) on all player accounts to reduce the risk of unauthorised account access;
• Regular security assessments: vpjl conducts periodic security reviews of its platform infrastructure to identify and address potential vulnerabilities;
• Incident response: vpjl maintains an internal data breach response procedure. In the event of a data breach that poses a risk to your rights and freedoms, vpjl will notify the relevant supervisory authority and affected players in accordance with applicable legal obligations.

While vpjl takes all reasonable steps to protect your data, no digital transmission or storage system is entirely immune to security risks. Players are encouraged to use strong, unique passwords and to enable 2FA on their vpjl accounts as an additional layer of personal protection.

As a data subject, you have the following rights with respect to the personal data vpjl holds about you. vpjl is committed to responding to all data rights requests within 30 calendar days of receipt.

To exercise any of these rights, please contact vpjl using the details provided in Section 15. vpjl may need to verify your identity before processing a data rights request to ensure the security of your personal information.

The vpjl platform is strictly prohibited for persons under the age of 21. vpjl does not knowingly collect personal data from anyone below the age of 21.

Age verification is a mandatory step in the vpjl account registration and KYC process. Where vpjl discovers that personal data has been collected from a person under the age of 21, that data will be deleted immediately, the Account will be permanently closed, and any associated balance will be dealt with in accordance with the vpjl Terms & Conditions.

If you believe that vpjl has inadvertently collected personal data from a minor, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

vpjl processes certain personal data specifically in the context of responsible gaming obligations. This processing is conducted in the interests of player welfare and regulatory compliance and includes:

• Recording and enforcing deposit limits, loss limits, and session time restrictions set by you through the Account dashboard;
• Recording and enforcing cool-off periods and self-exclusion orders, including maintaining exclusion records for the duration of the exclusion period and a minimum of five years thereafter;
• Monitoring account activity patterns for indicators of problem gambling behaviour, where vpjl may apply proactive responsible gaming measures in accordance with its responsible gaming obligations;
• Sharing self-exclusion information with third-party self-exclusion scheme operators where applicable and required by regulation.

Responsible gaming data is handled with particular care. Access to this data within vpjl is restricted to authorised personnel involved in responsible gaming operations and regulatory compliance. This data is not used for marketing or commercial profiling purposes.

For full details on vpjl's responsible gaming tools and how to use them, please visit the Responsible Gaming page.

vpjl reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or operational developments. Where changes are material, vpjl will notify registered players via the mobile number or email address on record at least 7 days before the changes take effect.

The date shown in the "Last Updated" notice at the top of this page reflects the most recent revision. We encourage players to review this Policy periodically to stay informed about how vpjl protects their personal data.

Your continued use of the vpjl platform following any amendment constitutes your acknowledgement of the updated Policy. If you do not agree with an amendment, you may request account closure by contacting vpjl player support before the amendment takes effect.

For all privacy-related enquiries, data rights requests, or complaints regarding vpjl's handling of your personal data, please contact us using the following details:

• Email: [email protected] — mark your subject line with "Privacy Request" or "Data Rights Request" for faster routing;
• In-platform support: Live chat available to logged-in account holders through the vpjl Account dashboard;
• Website: vpjl.club

vpjl will acknowledge all privacy-related requests within 5 business days and will provide a substantive response within 30 calendar days. Where a request is complex or involves a large volume of data, vpjl may extend this period by a further 30 days and will notify you accordingly.

If you are not satisfied with vpjl's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines, the independent supervisory authority responsible for enforcing data protection rights under the Data Privacy Act of 2012.