qpjl Privacy Policy – Your Data, Protected

qpjl ("we," "us," or "our") is the operator of the online gaming platform accessible at qpjl.club ("the Platform"). We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, including registered players, visitors, and prospective users.

This Privacy Policy has been prepared in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations ("IRR"), as enforced by the National Privacy Commission ("NPC"). It sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by qpjl.

This policy applies to all personal data collected through the qpjl Platform, including data collected via the website, mobile-optimized interfaces, customer support channels, and any other means through which you interact with qpjl. Please read this policy carefully. If you have any questions or concerns about how we handle your personal data, you can reach our Data Protection Officer using the contact details provided in Section 14.

qpjl collects personal data that is necessary for the operation of the Platform, the provision of gaming services, and compliance with our legal and regulatory obligations. The categories of personal data we collect include the following:

We collect only the minimum personal data necessary for the purposes described in this policy. We do not collect sensitive personal information such as racial or ethnic origin, political opinions, or religious beliefs unless specifically required by law.

qpjl collects personal data through the following means:

3.1 Direct Collection

We collect personal data directly from you when you register an account on the qpjl Platform, complete KYC verification, make a deposit or withdrawal, contact our customer support team, participate in promotions or surveys, or otherwise interact with the Platform in a way that requires you to provide personal information.

3.2 Automated Collection

When you access and use the qpjl Platform, we automatically collect certain technical and usage data through cookies, web beacons, log files, and similar tracking technologies. This includes your IP address, device identifiers, browser type, pages visited, time spent on the Platform, and game activity. This data is collected to ensure the security and proper functioning of the Platform and to improve the user experience.

3.3 Third-Party Sources

In certain circumstances, qpjl may receive personal data about you from third-party sources, including identity verification service providers, fraud prevention agencies, payment processors such as GCash and PayMaya, and regulatory databases. Data received from third parties is handled in accordance with this Privacy Policy and applicable law.

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

• Account Management: To create, maintain, and manage your qpjl player account, including processing your registration, verifying your identity, and enabling you to log in securely.
• Service Delivery: To provide you with access to the games, features, and services available on the qpjl Platform, including processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank.
• KYC and Regulatory Compliance: To verify your identity and age (21+), comply with anti-money laundering (AML) obligations, and meet all requirements imposed by applicable Philippine law and regulatory authorities.
• Responsible Gaming: To monitor your gaming activity for signs of problem gambling, enforce deposit and loss limits you have set, and administer self-exclusion requests in accordance with our Responsible Gaming policy.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, and other illegal or prohibited activities on the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our support channels.
• Marketing and Promotions: To send you information about qpjl promotions, bonuses, and platform updates, where you have provided your consent to receive such communications. You may withdraw your consent at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and content of the qpjl Platform.
• Legal Obligations: To comply with applicable laws, regulations, court orders, and requests from competent regulatory authorities, including PAGCOR and the National Privacy Commission.

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

• Contractual Necessity: Processing is necessary for the performance of the contract between you and qpjl — specifically, to provide you with access to the Platform and its services in accordance with our Terms and Conditions.
• Legal Obligation: Processing is necessary for qpjl to comply with its legal and regulatory obligations under Philippine law, including AML regulations, PAGCOR requirements, and the Data Privacy Act itself.
• Legitimate Interests: Processing is necessary for the purposes of qpjl's legitimate interests, including fraud prevention, platform security, and business analytics, provided that such interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as sending marketing communications and the use of non-essential cookies — we rely on your freely given, specific, informed, and unambiguous consent. You have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

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

6.1 Service Providers

We share personal data with trusted third-party service providers who assist us in operating the qpjl Platform. These include identity verification providers, payment processors (including GCash, PayMaya, BPI, BDO, and Metrobank), cloud hosting providers, customer support platforms, and analytics services. All service providers are contractually required to process your data only on our instructions and in accordance with applicable data protection law.

6.2 Regulatory and Legal Authorities

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

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of qpjl's business, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and ensure that your data continues to be protected in accordance with this Privacy Policy.

6.4 With Your Consent

We may share your personal data with other third parties where you have given your explicit consent for us to do so.

qpjl uses cookies and similar tracking technologies to enhance your experience on the Platform, ensure its security, and gather analytics data that helps us improve our services. A cookie is a small text file placed on your device when you visit a website.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as secure login, session management, and fraud prevention. These cookies cannot be disabled.
• Performance and Analytics Cookies: These cookies collect anonymized information about how visitors use the Platform, such as which pages are visited most frequently and whether error messages are received. This data helps us improve the Platform's performance.
• Functionality Cookies: These cookies allow the Platform to remember your preferences and settings, such as your preferred language and display options, to provide a more personalized experience.
• Marketing Cookies: These cookies are used to deliver promotional content that is relevant to your interests. They are only placed with your consent and can be disabled at any time through your browser settings.

7.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the qpjl Platform and your ability to access some features. For detailed instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

qpjl retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general rule, qpjl retains account and transaction data for a minimum of five (5) years following the closure of your account, in accordance with Philippine AML regulations and PAGCOR requirements. KYC verification documents are retained for the same minimum period.

Marketing preference data is retained until you withdraw your consent or request deletion. Technical and usage data collected through cookies and analytics tools is typically retained for a shorter period, as specified in our cookie settings.

When your personal data is no longer required for any lawful purpose, qpjl will securely delete or anonymize it in accordance with our internal data retention and disposal procedures.

qpjl implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include, but are not limited to:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the qpjl Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Strict access controls ensuring that personal data is accessible only to authorized qpjl personnel who require it to perform their duties.
• Regular security assessments, vulnerability testing, and penetration testing of the Platform's infrastructure.
• Two-factor authentication options for player accounts to reduce the risk of unauthorized access.
• Comprehensive staff training on data protection obligations and security best practices.

While qpjl 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, qpjl will notify the National Privacy Commission and, where required, affected individuals in accordance with the Data Privacy Act of 2012 and its IRR.

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

• Right to Be Informed: You have the right to be informed about how your personal data is being collected and processed, which is the primary purpose of this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data that qpjl holds about you, along with information about how it is being used.
• Right to Rectification: You have the right to request the correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have 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 our legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• 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, and to request that it be transmitted to another data controller 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 that qpjl has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14. We will respond to all valid requests within thirty (30) days of receipt. In some cases, we may need to verify your identity before processing your request.

The qpjl Platform is strictly intended for adults aged 21 years and above. qpjl does not knowingly collect personal data from individuals under the age of 21. Registration on the Platform by persons under 21 is prohibited, and qpjl employs age verification measures during the registration and KYC process to enforce this restriction.

If qpjl becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the qpjl Platform, please contact our support team immediately so that we can investigate and take appropriate action.

The qpjl Platform may contain references to third-party services, such as payment providers including GCash and PayMaya. When you interact with these third-party services, you will be subject to their own privacy policies and terms of use. qpjl is not responsible for the privacy practices or content of any third-party services and encourages you to review the privacy policies of any third parties you interact with in connection with your use of the Platform.

The inclusion of any reference to a third-party service on the qpjl Platform does not constitute an endorsement of that service's privacy practices by qpjl.

qpjl reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When we make material changes to this policy, we will notify registered players via email or through a prominent notice on the Platform prior to the changes taking effect.

The effective date at the top of this page will always reflect the date on which the most recent version of the Privacy Policy came into force. We encourage you to review this page periodically to stay informed about how qpjl is protecting your personal data. Your continued use of the Platform following the posting of any changes constitutes your acceptance of the updated Privacy Policy.

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

All privacy-related inquiries will be acknowledged within five (5) business days and resolved within thirty (30) days, in accordance with the requirements of the Data Privacy Act and its IRR. Please include your registered account username and a clear description of your request or concern to help us assist you efficiently.

If you are not satisfied with our response to your privacy concern, you have the right to escalate your complaint directly to the National Privacy Commission of the Philippines.