jmmm Privacy Policy

This Privacy Policy ("Policy") describes how jmmm ("jmmm", "we", "us", or "our") collects, uses, stores, and discloses personal data relating to individuals ("you", "Player", "Data Subject") who access or use the jmmm online casino and sports betting platform available at https://jmmm.asia and all associated services (collectively, the "Platform").

jmmm operates primarily to serve Filipino players and is committed to complying with the Republic Act No. 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC) of the Philippines. Where additional obligations arise from international data protection frameworks relevant to our operations, we observe those obligations as well.

This Policy forms part of jmmm's complete legal framework alongside the Terms & Conditions and Responsible Gaming Policy. By registering an Account on the jmmm Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

For the purposes of applicable Philippine data privacy law, jmmm is the Personal Information Controller (PIC) responsible for your personal data collected through the Platform. jmmm determines the purposes for which, and the means by which, your personal data is processed.

jmmm has appointed a Data Protection Officer (DPO) as required under the Data Privacy Act of 2012. The DPO is responsible for overseeing jmmm's compliance with this Policy and applicable data privacy law, and for handling data subject rights requests and privacy-related inquiries.

You may contact the jmmm Data Protection Officer at any time by writing to: [email protected] with the subject line "Data Privacy – DPO Request". Please include your full registered name, Account username, and a clear description of your inquiry or request to enable the DPO to locate your Account and respond efficiently.

jmmm collects the following categories of personal data. We collect only what is necessary for the specific purposes identified in Section 5 of this Policy — no more.

jmmm does not intentionally collect sensitive personal information (as defined under the Data Privacy Act of 2012) beyond what is strictly necessary for KYC verification. Government ID data is processed solely for identity verification purposes and is not used for any other purpose without your explicit consent.

jmmm collects personal data through the following channels:

• Direct Collection: Data you provide when registering an Account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or setting responsible gaming preferences.
• Automated Collection: Technical data collected automatically when you access and use the jmmm Platform, including through cookies, web beacons, and server logs. See Section 9 for full details on our use of cookies.
• Payment Processors: Transaction confirmation data received from our payment processing partners (GCash, Maya, BPI, BDO, UnionBank, 7-Eleven Cliqq, USDT TRC20, Coins.ph) in connection with deposits and withdrawals you initiate.
• Identity Verification Partners: Results of identity verification checks conducted through our KYC service providers, which cross-reference the documents you submit against relevant databases.
• Fraud Prevention Services: Risk signals and device fingerprinting data provided by third-party fraud prevention services used to protect the integrity of the Platform and the security of all Players' accounts.

jmmm processes your personal data only where a valid legal basis exists under the Data Privacy Act of 2012. The following table sets out each processing purpose and the corresponding legal basis:

jmmm does not sell, rent, or trade your personal data to any third party. Your data is shared only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Processing Partners: Your transaction data is shared with the payment processors you select (e.g., GCash, Maya, BPI) solely to execute deposits and withdrawals. These partners operate under their own privacy policies and data protection obligations.
• KYC and Identity Verification Providers: Identity documents submitted for KYC purposes are processed by our licensed identity verification service providers. These providers are contractually bound to process your data only for identity verification purposes on jmmm's behalf.
• Game Software Providers: Anonymized or session-level gaming activity data may be shared with our game software providers (such as PG Soft, Jili, Pragmatic Play) for game integrity and technical support purposes. Individual player identity is not disclosed to game providers.
• Fraud Prevention and Security Services: Technical and behavioral data may be shared with fraud prevention service providers to protect the Platform and all Players from fraudulent activity, account takeover attempts, and financial crime.
• Regulatory and Law Enforcement Authorities: jmmm will disclose personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), law enforcement agencies, or other competent Philippine government authorities where required to do so by law, regulation, court order, or official request.
• Legal and Professional Advisors: Personal data may be disclosed to jmmm's legal counsel, auditors, or other professional advisors on a strictly confidential and need-to-know basis where necessary for the conduct of legitimate legal or compliance proceedings.

jmmm retains your personal data for as long as is necessary to fulfil the purposes for which it was collected and to comply with applicable legal obligations. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your active Account plus a minimum of five (5) years following Account closure, in compliance with Philippine AML regulations and PAGCOR record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine AML law.
• Gaming Activity Data: Retained for three (3) years from the date of each gaming session, unless a longer period is required by applicable law or regulatory investigation.
• KYC Documents: Retained for the duration of your Account plus five (5) years following Account closure, in line with regulatory requirements.
• Customer Support Communications: Retained for three (3) years from the date of each communication, or longer where the communication is relevant to an ongoing dispute or legal proceeding.
• Technical and Analytical Data: Retained in anonymized or aggregated form for up to two (2) years for platform improvement and analytics purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with any individual Player.

jmmm 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:

• Transport Encryption: All data transmitted between your device and the jmmm Platform is encrypted using 256-bit SSL/TLS protocols, ensuring that your credentials and personal data cannot be intercepted in transit.
• Password Hashing: Your jmmm Account password is never stored in plain text. It is stored as a one-way cryptographic hash, meaning that even jmmm's own engineers cannot read your password.
• Access Controls: Access to personal data within jmmm's systems is restricted to employees and contractors who require it to perform their legitimate job functions. Access is governed by role-based permissions and logged for audit purposes.
• Two-Factor Authentication: jmmm supports SMS-based two-factor authentication for Player Accounts. We strongly encourage all Players to enable 2FA to further protect their Account and personal data.
• Intrusion Detection and Monitoring: jmmm's infrastructure is monitored 24/7 for suspicious activity, unauthorized access attempts, and security anomalies. Automated alerts trigger immediate investigation by jmmm's security team.
• Vendor Security Requirements: All third-party service providers who process personal data on jmmm's behalf are required to maintain security standards consistent with or exceeding those applied by jmmm.
• Data Breach Response: In the event of a personal data breach that poses a risk to the rights and freedoms of affected individuals, jmmm will notify the National Privacy Commission and affected Players within the timeframes required by law.

jmmm uses cookies and similar tracking technologies on the Platform to provide a functional and secure experience. The following types of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the jmmm Platform to function. They enable core functionality such as session authentication, security token management, and shopping cart persistence. These cookies cannot be disabled without severely impacting Platform functionality.
• Functional Cookies: These cookies remember your preferences (such as language settings and responsible gaming configurations) to provide a personalized experience across sessions.
• Performance and Analytics Cookies: These cookies collect anonymized data about how Players use the jmmm Platform — which pages are visited most frequently, how long sessions last, and where errors occur. This data is used to improve Platform performance and user experience. jmmm does not link analytics data back to individual Player identities.
• Security Cookies: These cookies support jmmm's fraud detection and account protection systems by identifying patterns that may indicate unauthorized access or bot activity.

jmmm does not use cookies to serve third-party advertising or to track your activity outside of the jmmm Platform. You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in to and using the jmmm Platform.

The jmmm Platform is strictly intended for individuals aged 21 years and above. This is the minimum legal age for participation in all forms of online gambling in the Philippines. jmmm does not knowingly collect personal data from individuals under the age of 21.

If jmmm discovers or has reasonable grounds to believe that personal data has been collected from an individual under the age of 21, jmmm will:

• Immediately suspend the associated Account pending investigation.
• Delete the personal data of the underage individual to the extent permitted by law.
• Return any deposited funds in accordance with applicable regulations.
• Report the matter to the relevant Philippine regulatory authorities where required.

If you are a parent or guardian and you believe that your child under the age of 21 has created an Account on the jmmm Platform or has provided personal data to jmmm, please contact our Data Protection Officer immediately at [email protected] so that we can take prompt action.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jmmm. You may exercise any of these rights by contacting the jmmm Data Protection Officer at [email protected]:

• Right to Be Informed: The right to be informed of the existence of processing activities involving your personal data, including the purposes for which your data is processed. This Policy fulfils jmmm's obligation to inform you.
• Right of Access: The right to obtain a copy of the personal data that jmmm holds about you and information about how that data is being processed. jmmm will respond to verified access requests within fifteen (15) business days.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. You may update basic Account information directly through your Account settings; for other corrections, contact the DPO.
• Right to Erasure or Blocking: The right to request the deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, where consent has been withdrawn, or where the processing is unlawful. Please note that erasure may not be possible where retention is required by law (e.g., AML record-keeping 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 transmit that data to another data controller where technically feasible.
• Right to Object: The right to object to processing of your personal data based on jmmm's legitimate interests, including direct marketing communications. Objection to direct marketing will be honored without question.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that jmmm has violated your data privacy rights. jmmm encourages you to contact us first to resolve any concern before escalating to the NPC.

Some of jmmm's service providers — including certain game software providers, fraud prevention services, and technical infrastructure providers — may process personal data outside of the Philippines. When jmmm transfers personal data to third parties in other jurisdictions, we ensure that adequate safeguards are in place to protect your data, including:

• Contractual clauses that require the receiving party to protect your personal data to a standard consistent with the Philippine Data Privacy Act of 2012.
• Transfers only to jurisdictions that have been determined by the National Privacy Commission to provide an adequate level of data protection.
• Additional technical safeguards such as pseudonymization or anonymization of personal data before transfer, where practicable.

Where jmmm relies on contractual clauses as the basis for an international transfer, you may request a copy of the applicable clauses by contacting the Data Protection Officer.

jmmm may, with your explicit consent, send you promotional communications about new games, bonuses, and offers available on the jmmm Platform. Marketing communications are sent via email or SMS to your registered contact details.

You may withdraw consent to receive marketing communications at any time by:

• Clicking the "Unsubscribe" link in any marketing email sent by jmmm.
• Replying "STOP" to any marketing SMS sent by jmmm.
• Updating your communication preferences in the Account Settings section of the jmmm Platform.
• Contacting jmmm's customer support or the Data Protection Officer with a written unsubscribe request.

Withdrawal of consent to marketing communications does not affect the lawfulness of any processing carried out before the withdrawal, and will not prevent jmmm from sending you transactional communications that are necessary for the operation of your Account (such as deposit confirmations, withdrawal notifications, and security alerts).

jmmm may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory guidance. The date of the most recent revision is displayed at the top of this Policy.

Where a change to this Policy materially affects the way in which we process your personal data, jmmm will notify you by email to your registered address and by posting a prominent notice on the jmmm Platform at least seven (7) days before the change takes effect. We encourage you to review this Policy periodically.

Your continued use of the jmmm Platform following the effective date of a revised Privacy Policy constitutes your acknowledgment of the updated terms. If you do not accept the revised Policy, you must cease using the Platform and may request Account closure by contacting customer support.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by jmmm, you may contact the jmmm Data Protection Officer through the following channel:

Email: [email protected] — Subject line: "Data Privacy – DPO Request"

You may also contact jmmm's general customer support team via the live chat function available on the jmmm Platform, available 24 hours a day, 7 days a week, in both English and Tagalog.

For escalations or formal complaints that jmmm has been unable to resolve to your satisfaction, you may contact the National Privacy Commission (NPC) of the Philippines via the NPC's official website and complaint portal.