jmmm Privacy Policy

This Privacy Policy ("Policy") applies to the personal information collected and processed by jmmm ("jmmm," "we," "our," or "us") in connection with your use of the jmmm online gaming platform accessible at jmmm.one (the "Platform"), including all associated applications, features, services, and communications.

jmmm is the Data Controller with respect to personal information collected from players and visitors of the Platform. As Data Controller, jmmm determines the purposes and means of processing personal data in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations.

This Policy forms part of jmmm's broader Terms and Conditions. By registering an account or otherwise using the jmmm Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal information as described herein.

jmmm collects the following categories of personal information from registered players and Platform visitors:

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (for age verification — 21+ requirement)
• Nationality and country of residence
• Residential address (barangay, city/municipality, province)
• Philippine mobile number (used as your primary account identifier)
• Email address (for account communications and notifications)

• Government-issued Philippine ID (e.g., PhilSys National ID, passport, driver's license, UMID, SSS/GSIS ID, voter's ID)
• Selfie or live photo for biometric verification
• Proof of address documents where required
• Source of funds documentation for high-value account activity

• GCash or Maya mobile wallet identifiers (tokenized; full account credentials are never stored by jmmm)
• Bank account names and last 4 digits (for withdrawal reconciliation)
• Deposit history, withdrawal history, and net gaming revenue per account
• Bonus usage and promotion redemption history

• IP address at time of login and account activity
• Device type, operating system, and browser information
• Session timestamps, session duration, and navigation patterns within the Platform
• Game history: titles played, bet amounts, outcomes, and session data
• Geolocation data at the jurisdiction level (country/region, not precise GPS)

jmmm collects personal data through the following means:

• Registration: Data you provide when creating your jmmm account, including identity information and contact details.
• KYC Verification: Documents and photos submitted during the identity verification process.
• Transactions: Payment data generated when you deposit or withdraw using GCash, Maya, or bank transfer.
• Platform Usage: Automatically collected technical and behavioral data as you navigate and interact with the jmmm Platform.
• Cookies and Similar Technologies: Session and analytics data collected through cookies and web tracking technologies (see Section 6).
• Customer Support Interactions: Data you provide when contacting the jmmm support team via live chat or email.
• Third-Party Sources: Identity and fraud verification data from accredited third-party KYC service providers and payment processors, where applicable.

jmmm processes your personal data on the following legal bases and for the following purposes:

jmmm does not sell, rent, or trade your personal information. We share personal data only in the following circumstances and with the following categories of recipients:

jmmm engages third-party service providers to support Platform operations, including payment processors (GCash/Maya integration partners), KYC verification providers, cloud hosting services, and customer support platforms. These parties process data solely on jmmm's instructions and are bound by data processing agreements consistent with RA 10173 requirements.

jmmm will disclose personal data to competent Philippine government authorities — including but not limited to the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies — when required to do so by law, court order, or regulatory directive.

In the event of a merger, acquisition, or sale of all or substantially all of jmmm's assets, personal data held by jmmm may be transferred to the successor entity. Players will be notified of such a transfer and provided an opportunity to exercise their data rights prior to the transfer completing.

jmmm uses cookies and similar tracking technologies on the Platform to ensure proper functionality, enhance your user experience, maintain your session, and gather aggregated analytics. The types of cookies deployed by jmmm include:

• Strictly Necessary Cookies: Required for login session management, security, and basic Platform functionality. These cannot be disabled.
• Functional Cookies: Remember your preferences (e.g., language, last played games) to personalize your jmmm experience.
• Analytics Cookies: Collect aggregated, anonymized data about how players navigate the Platform, used to identify and resolve usability issues.
• Fraud Prevention Cookies: Detect and prevent duplicate accounts, fraudulent transactions, and abuse of promotional offers.

You may manage or disable non-essential cookies through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log in and use the jmmm Platform.

jmmm retains personal data for as long as necessary to fulfill the purposes described in this Policy or as required by applicable law. Specific retention periods include:

• Account data and transaction records: Retained for a minimum of five (5) years from the date of account closure, in compliance with AML record-keeping requirements under RA 9160.
• KYC and identity documents: Retained for the duration of the account relationship plus five (5) years following closure.
• Technical and usage logs: Retained for up to twelve (12) months for security monitoring and fraud investigation purposes.
• Customer support correspondence: Retained for up to three (3) years for dispute resolution and quality assurance purposes.

Upon expiry of applicable retention periods, jmmm will securely delete or anonymize your personal data in accordance with NPC-approved data disposal procedures.

jmmm implements technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jmmm servers
• Encrypted storage of sensitive data at rest using AES-256 or equivalent standards
• Access controls ensuring only authorized jmmm personnel can access personal data, on a need-to-know basis
• Regular security audits, penetration testing, and vulnerability assessments of Platform infrastructure
• Multi-factor authentication requirements for jmmm staff with access to player data systems
• Employee data privacy training and confidentiality agreements for all staff handling personal data

While jmmm takes all reasonable steps to protect your data, no security system is entirely impenetrable. Players are encouraged to maintain strong, unique passwords for their jmmm account and to enable SMS two-factor authentication through their account settings.

Under Republic Act No. 10173 and applicable NPC regulations, Filipino data subjects have the following rights with respect to personal data held by jmmm:

• Right to be Informed: The right to know what personal data jmmm collects, how it is used, and to whom it is disclosed — as documented in this Policy.
• Right to Access: The right to request a copy of the personal data jmmm holds about you, free of charge, once per calendar year.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by jmmm.
• Right to Erasure or Blocking: The right to request deletion or blocking of personal data where processing is no longer necessary, where consent has been withdrawn, or where processing is unlawful — subject to legal retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format for transfer to another controller.
• Right to Object: The right to object to processing based on legitimate interest, including profiling for direct marketing purposes.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jmmm has violated your data privacy rights.

To exercise any of the above rights, contact jmmm's Data Protection Officer at the address provided in Section 13. jmmm will respond to verified requests within thirty (30) days, consistent with NPC timelines.

The jmmm Platform is strictly prohibited for individuals under the age of twenty-one (21) years. jmmm does not knowingly collect personal information from persons below this age. Age verification is conducted during the account registration process and, where necessary, through document-based KYC.

If jmmm discovers that personal data has been collected from an individual below the minimum age requirement, the account will be immediately closed, all balances forfeited, and the associated personal data will be deleted in accordance with jmmm's data disposal procedures. Parents or guardians who believe a minor has accessed the jmmm Platform are encouraged to notify jmmm immediately via the contact details in Section 13.

jmmm's primary operations and data processing infrastructure are located within the Philippines. In certain circumstances, personal data may be transferred to and processed by service providers operating in other jurisdictions — for example, cloud infrastructure providers or KYC verification services with international operations.

All cross-border data transfers by jmmm are subject to appropriate safeguards, including contractual data protection clauses that provide protections equivalent to those available under Philippine data privacy law. jmmm will not transfer personal data to a foreign jurisdiction unless adequate protections are in place and the transfer is consistent with RA 10173 requirements.

jmmm reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered players via email notification or a prominent notice on the Platform at least fourteen (14) days prior to the changes taking effect, where practicable. The "Last Updated" date at the top of this Policy reflects the most recent revision.

Continued use of the jmmm Platform following the effective date of any amended Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Privacy Policy, you may request account closure by contacting jmmm support.

If you have questions, concerns, or requests relating to this Privacy Policy or jmmm's handling of your personal data, please contact jmmm's Data Protection Officer (DPO):

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 under RA 10173 have been violated. NPC contact information is publicly available on the NPC's official government website.