sealjl Privacy Policy

1 About This Policy

1.1 This Privacy Policy applies to all personal data collected by sealjl through the sealjl website, mobile browser experience, and any sealjl applications, as well as through customer support interactions, KYC verification processes, and promotional communications.

1.2 This Policy should be read alongside sealjl's Terms & Conditions and Responsible Gaming Policy, which together form the complete legal framework governing your use of the sealjl platform. By registering a sealjl account or by continuing to use the platform after this Policy has been updated, you confirm your acceptance of its terms.

1.3 sealjl is committed to the principles of transparency, proportionality, and data minimization. We collect only what is necessary for the purposes described in this Policy and retain data only for as long as those purposes require or as mandated by applicable Philippine law.

2 Data Controller

2.1 sealjl is the data controller responsible for your personal data processed in connection with your use of the platform. As data controller, sealjl determines the purposes and means of processing personal data and is accountable for ensuring that all processing activities comply with the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations.

2.2 sealjl has appointed a Data Protection Officer (DPO) as required under the Data Privacy Act. The DPO is responsible for overseeing data protection strategy and implementation, and for acting as the primary point of contact for data subject rights requests and privacy enquiries. Contact details for the DPO are provided in Section 16 of this Policy.

2.3 sealjl is registered with the National Privacy Commission (NPC) of the Philippines as a personal information controller, in accordance with NPC registration requirements applicable to entities processing the personal data of Philippine residents at scale.

3 Data We Collect

3.1 sealjl collects the following categories of personal data from players and platform users. The specific data collected depends on the nature of your interaction with sealjl and the stage of the account lifecycle you are in:

• Full legal name as it appears on your government-issued ID
• Date of birth (used for 21+ age verification)
• Registered Philippine address (province, city, barangay)
• Email address and mobile phone number
• Username and hashed account password
• Nationality and, where applicable, Philippine government ID number

• Copies of government-issued photo IDs (e.g., Philippine Passport, PhilSys National ID, UMID, SSS ID, Driver's License, PRC ID, Voter's ID)
• Proof of address documents (e.g., utility bills, bank statements, barangay certificates)
• Selfie photographs submitted for identity verification purposes
• Proof of payment method ownership (e.g., GCash or PayMaya account screenshots showing registered name)

• Deposit and withdrawal transaction records including amounts, timestamps, and payment method references
• GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay account identifiers (account names and reference numbers — never full account credentials)
• Account balance history and bonus transaction records
• Chargeback and dispute records where applicable

• Game session logs including game titles played, session durations, wager amounts, and win/loss outcomes
• Bonus activation and wagering requirement completion records
• Responsible gaming tool settings (deposit limits, session reminders, self-exclusion status)
• Sports betting selections, live casino session records, bingo card history, and slot spin logs

• IP address and geolocation data (used to verify Philippine location and detect VPN/proxy use)
• Device type, operating system, browser type and version
• Session timestamps, page interaction logs, and navigation paths
• Cookie identifiers and analytics tracking data (see Section 8)

• Customer support chat transcripts, email correspondence, and support ticket records
• Responses to surveys, promotions, or feedback requests
• Records of marketing communication consent and opt-out preferences

4 How We Collect Your Data

4.1 sealjl collects personal data through the following methods:

• Direct collection: Information you provide when you register an account, complete KYC verification, make deposits or withdrawals, contact customer support, or respond to promotions.
• Automatic collection: Technical and device data collected automatically when you access and use the sealjl platform, including IP addresses, session logs, and cookie data.
• Third-party sources: Identity verification data may be cross-referenced with Philippine government databases or third-party KYC service providers for fraud prevention and regulatory compliance purposes. Payment data is received from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank to confirm transaction completion.
• Regulatory sources: sealjl may receive information from PAGCOR or other Philippine regulatory authorities related to self-exclusion registers, prohibited player lists, or compliance directives.

5 Purpose & Legal Basis for Processing

5.1 sealjl processes your personal data only where a lawful basis for processing exists under the Philippine Data Privacy Act of 2012. The following table summarizes the primary processing purposes and their corresponding legal bases:

5.2 Where sealjl relies on consent as the legal basis for processing (e.g., marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

6 How We Use Your Data

6.1 sealjl uses your personal data for the following purposes, consistent with the legal bases described in Section 5:

• To create, verify, and maintain your sealjl player account, including enforcing the one-account-per-player rule.
• To verify your identity and age (must be 21 years or older) as required by PAGCOR licensing conditions and Philippine law.
• To process your deposits and withdrawals in Philippine Peso via GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay.
• To deliver the games, services, bonuses, and promotions you access on the sealjl platform.
• To detect and prevent fraud, collusion, multi-accounting, money laundering, and other prohibited activities.
• To comply with PAGCOR regulatory reporting obligations and AMLC suspicious transaction reporting requirements.
• To enforce responsible gaming measures including deposit limits, cool-off periods, and self-exclusion.
• To communicate with you about your account, transactions, promotions (where you have consented), and important platform updates.
• To improve the sealjl platform through anonymized usage analytics and performance monitoring.
• To resolve customer support queries, complaints, and disputes in a timely and fair manner.

6.2 sealjl will not use your personal data for any purpose that is incompatible with the purposes listed above without first providing you with notice and, where required by law, obtaining your consent.

7 Data Sharing & Disclosure

7.1 sealjl does not sell, rent, or commercially trade your personal data to any third party. Data is shared only in the following limited and controlled circumstances:

• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities where required by law, court order, or regulatory directive.
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, and other approved payment partners receive limited transactional data necessary to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party identity verification services that assist sealjl in fulfilling KYC obligations under PAGCOR regulations. These providers operate under strict data processing agreements consistent with the Philippine Data Privacy Act.
• Game content providers: Third-party game studios and live casino platform providers (such as JILI and live dealer studios) may receive anonymized session data necessary to deliver game content. No personally identifiable data is shared beyond what is technically required.
• IT and security service providers: Cloud hosting, cybersecurity, fraud detection, and platform infrastructure providers who process data solely on sealjl's instructions under appropriate data processing agreements.
• Professional advisors: Legal counsel, auditors, and compliance consultants who are bound by professional confidentiality obligations and who access data only as strictly necessary for the advisory service.

8 Cookies & Tracking Technologies

8.1 sealjl uses cookies and similar tracking technologies to deliver and improve the platform experience. A cookie is a small text file stored on your device when you visit a website. sealjl uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred games, and display options to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how users interact with the platform — pages visited, time spent, navigation paths — to help sealjl improve user experience. sealjl uses privacy-respecting analytics tools that do not build advertising profiles.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized account access attempts.

8.2 sealjl does not use advertising or third-party retargeting cookies that track your activity across external websites. You may manage or delete cookies at any time through your browser's settings. Note that disabling strictly necessary cookies will impair your ability to use the sealjl platform.

9 Data Retention

9.1 sealjl retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the minimum retention periods required by Philippine law and PAGCOR regulations. The following general retention periods apply:

• Active account data: Retained for the duration of your active account relationship with sealjl.
• KYC and identity verification records: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years, consistent with Philippine anti-money laundering and tax record-keeping obligations.
• Customer support records: Retained for three (3) years from the date of the final interaction, unless a dispute or legal claim is pending.
• Marketing consent records: Retained for the duration of your account and for three (3) years after withdrawal of consent or account closure, to demonstrate compliance with consent requirements.
• Technical and device logs: Retained for up to twelve (12) months for security and fraud investigation purposes.

9.2 Upon expiry of the applicable retention period, sealjl will securely delete or anonymize your personal data. Where anonymization is used, the resulting data no longer constitutes personal data and may be retained indefinitely for statistical and analytical purposes.

10 Data Security

10.1 sealjl implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• TLS 1.3 encryption for all data transmitted between your device and sealjl's servers.
• AES-256 encryption for sensitive data stored at rest, including identity documents and payment references.
• Multi-factor authentication (MFA) options for player accounts and mandatory MFA for all sealjl internal system access.
• Regular independent penetration testing and vulnerability assessments by certified cybersecurity professionals.
• Strict role-based access controls ensuring that sealjl staff can only access personal data relevant to their specific job functions.
• Comprehensive data breach response procedures, including NPC notification within 72 hours of discovering a breach that poses a real risk to data subjects.
• Regular staff training on data protection obligations, phishing awareness, and secure data handling practices.

10.2 While sealjl takes all reasonable precautions to secure your personal data, no internet transmission or electronic storage system is completely secure. sealjl encourages players to use strong, unique passwords for their accounts and to enable all available account security features.

11 Your Data Subject Rights

11.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by sealjl. These rights may be exercised by contacting the sealjl Data Protection Officer at [email protected]:

• Right to be Informed: You have the right to know what personal data sealjl collects about you, how it is used, and with whom it is shared — which is the primary purpose of this Privacy Policy.
• Right of Access: You may request a copy of the personal data sealjl holds about you, along with information about how it is being processed.
• Right to Rectification: If any of your personal data held by sealjl is inaccurate or incomplete, you have the right to request that it be corrected or updated promptly.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations (e.g., AMLC record-keeping requirements).
• Right to Object: You may object to the processing of your personal data for marketing purposes at any time. You may also object to processing based on legitimate interest where you have grounds relating to your particular situation.
• Right to Data Portability: Where technically feasible, you may request that sealjl provide your personal data in a structured, commonly used, machine-readable format for transfer to another data controller.
• Right to Lodge a Complaint: If you believe sealjl has not handled your personal data in accordance with the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11.2 sealjl will respond to all data subject rights requests within thirty (30) days of receipt. Where a request is complex or involves a large volume of data, sealjl may extend this period by a further thirty (30) days, with prior notice to you. sealjl will not charge a fee for exercising your data subject rights unless requests are manifestly unfounded or excessive.

12 Children's Privacy & Age Restriction

12.1 sealjl's platform is strictly restricted to persons who are 21 years of age or older, in accordance with PAGCOR regulations governing online gambling in the Philippines. sealjl does not knowingly collect personal data from individuals under 21 years of age.

12.2 During the registration process, sealjl collects date of birth information and cross-references it against KYC documentation to verify age compliance. Any account found to have been registered by a person under 21 years of age will be immediately and permanently closed, all associated balances will be forfeited, and all personal data associated with the account will be securely deleted except where retention is required for legal reporting purposes.

13 International Data Transfers

13.1 sealjl primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, for example where sealjl uses cloud infrastructure services or game content delivery networks with servers in other jurisdictions.

13.2 Where personal data is transferred outside the Philippines, sealjl ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that provided under the Philippine Data Privacy Act. Such safeguards include contractual data processing agreements incorporating the NPC's standard contractual clauses or equivalent protections recognized under applicable Philippine law.

13.3 sealjl does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

14 Third-Party Links

14.1 The sealjl platform may contain links to third-party websites or services for informational purposes, such as PAGCOR's official website or Philippine banking institution websites. sealjl is not responsible for the privacy practices, content, or data security of any third-party website. This Privacy Policy applies solely to data collected by sealjl and does not extend to any third-party platforms.

14.2 sealjl recommends that you review the privacy policies of any third-party websites you visit through links on the sealjl platform, particularly before providing any personal information to those sites.

15 Amendments to This Policy

15.1 sealjl reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance from the NPC or PAGCOR, or changes in sealjl's data processing practices. The most current version of this Policy will always be available at https://sealjl.bet/privacy-policy, with the effective date of the most recent revision indicated at the top of the document.

15.2 Where sealjl makes material changes to this Privacy Policy — changes that meaningfully affect your rights or how your personal data is processed — sealjl will provide advance notice via registered email or prominent in-platform notification at least seven (7) days before the changes take effect.

15.3 Your continued use of the sealjl platform following the effective date of an updated Privacy Policy constitutes your acknowledgment of and agreement to the revised terms. If you do not agree with the revised Policy, you should cease using the platform and may request account closure in accordance with the Terms & Conditions.

16 Contact & Data Protection Officer

16.1 For any questions, concerns, or requests relating to this Privacy Policy or to your personal data held by sealjl, please contact sealjl's Data Protection Officer through the following channel:

16.2 If you are not satisfied with sealjl's response to your privacy enquiry or data subject rights request, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the independent regulatory authority responsible for enforcing the Data Privacy Act of 2012. NPC contact and complaint submission information is publicly available on the NPC's official website.

16.3 This Privacy Policy was last reviewed and updated in January 2026. sealjl's Data Protection Officer reviews this Policy at least annually and following any significant changes to applicable data protection law or sealjl's processing activities.