Privacy Policy

This Privacy Policy ("Policy") describes how jq101 ("jq101," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "Player," or "User") who access or use the jq101 online gaming platform, including the website at jq101.net and any associated mobile applications or services (collectively, the "Platform").

By registering an account, accessing the Platform, or otherwise providing your personal information to jq101, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

This Policy should be read alongside jq101's Terms & Conditions, which govern your use of the Platform more broadly. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, jq101 is the Personal Information Controller in respect of the personal data collected through the Platform. jq101 determines the purposes and means of processing your personal information and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

Where jq101 engages third-party service providers to process personal data on its behalf, those providers act as Personal Information Processors and are contractually bound to process data only on jq101's documented instructions and in accordance with applicable data privacy law.

For all data privacy enquiries, requests, or complaints, you may contact jq101's designated Data Protection Officer (DPO) at: [email protected]

jq101 collects the following categories of personal data:

3.1 Identity & Contact Data

• Full legal name as it appears on a valid government-issued ID.
• Date of birth (for age verification — players must be 21 or older).
• Nationality and country of residence.
• Registered email address.
• Philippine mobile number.
• Residential address.

3.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID).
• Proof of address documents (e.g., utility bills, bank statements).
• Selfie or facial image for liveness verification, where required.

3.3 Financial Data

• GCash or PayMaya / Maya account reference (masked).
• Bank account details (masked) for withdrawal processing.
• Transaction history: deposits, withdrawals, and wager records.

3.4 Gaming & Behavioural Data

• Game play history, bet amounts, win/loss records, and session durations.
• Bonus and promotion usage history.
• Responsible gaming tool usage (deposit limits set, self-exclusion requests).

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP.
• Device type, operating system, and browser type.
• Unique device identifiers.
• Log data: pages visited, features used, timestamps, and error logs.

3.6 Communications Data

• Records of communications with jq101 support (chat transcripts, email correspondence).
• Survey responses and feedback submitted voluntarily.

jq101 collects personal data through the following means:

• Direct provision: Information you provide when registering, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and device data collected automatically when you access the Platform via cookies, web beacons, and server logs.
• Third-party sources: Identity verification providers, payment processors (GCash, Maya, banks), fraud prevention services, and regulatory databases — where permitted by law.
• Publicly available sources: Sanctions lists, politically exposed persons (PEP) databases, and other publicly available compliance databases consulted as part of our AML/KYC obligations.

jq101 processes your personal data for the following purposes:

jq101 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and jq101 (i.e., providing gaming services, processing transactions, managing your account).
• Legal obligation: Processing required to comply with applicable laws and regulations, including PAGCOR licensing requirements, AML obligations, and tax reporting.
• Legitimate interests: Processing necessary for jq101's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where your prior consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of prior processing.

jq101 does not sell your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya / Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and liveness-check service providers engaged to verify your identity and age.
• Fraud and AML screening services: Providers of sanctions screening, PEP checks, and fraud detection tools.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers who process data on jq101's behalf under strict data processing agreements.
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where required by law or regulatory instruction.
• Legal and professional advisers: Lawyers, auditors, and accountants, subject to professional confidentiality obligations.

All third-party processors engaged by jq101 are contractually required to implement appropriate technical and organisational security measures and to process personal data only in accordance with jq101's documented instructions.

jq101 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with jq101's data disposal procedures.

jq101 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption of data in transit using TLS 1.2 or higher.
• Encryption of sensitive data at rest using industry-standard algorithms.
• Role-based access controls limiting staff access to personal data on a need-to-know basis.
• Multi-factor authentication for internal systems handling personal data.
• Regular security assessments, penetration testing, and vulnerability scanning.
• Staff training on data privacy and information security obligations.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

jq101 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse usage patterns. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function (e.g., session authentication, security tokens). These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options.
• Analytics cookies: Collect aggregated, anonymised data about how players use the Platform to help us improve the user experience.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your prior consent.

You may manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Platform. Consent for non-essential cookies may be withdrawn at any time.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jq101:

To exercise any of these rights, please contact jq101's Data Protection Officer at [email protected]. jq101 will respond to all verified requests within 30 calendar days. We may request proof of identity before processing your request.

Please note that certain rights are subject to limitations where processing is required for legal compliance, fraud prevention, or the establishment, exercise, or defence of legal claims.

The jq101 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations. jq101 does not knowingly collect personal data from persons under the age of 21.

If jq101 becomes aware that personal data has been collected from a person under 21, that account will be immediately closed, all data will be deleted in accordance with applicable law, and any balance will be handled in accordance with jq101's Terms & Conditions and regulatory requirements.

If you believe that a minor has registered on jq101, please contact us immediately at [email protected].

Some of jq101's third-party service providers (such as cloud infrastructure or identity verification providers) may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection, jq101 ensures that appropriate safeguards are in place, such as contractual clauses approved by the National Privacy Commission or equivalent mechanisms.

jq101 will not transfer your personal data internationally unless such transfer is necessary for the performance of your contract, required by law, or subject to adequate safeguards as described above.

jq101 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. The revised Policy will be posted on this page with an updated "Last updated" date. Where changes are material, jq101 will provide notice via email or an in-platform notification prior to the changes taking effect.

Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this page periodically.

For any questions, concerns, or requests relating to this Privacy Policy or jq101's handling of your personal data, please contact our Data Protection Officer:

Email: [email protected]

If you are not satisfied with jq101's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

Please include your registered username, a description of your concern, and any relevant supporting information when contacting us. We aim to acknowledge all privacy requests within 5 business days and resolve them within 30 calendar days.