Privacy Policy

1Introduction

jmmm Casino ("jmmm," "we," "us," or "our"), operator of the online gaming platform accessible at jmmm.cam, recognizes that the privacy and security of personal information entrusted to us by Filipino players is a fundamental obligation — not an afterthought. This Privacy Policy ("Policy") sets out in clear, plain terms how jmmm collects, processes, stores, shares, and protects the personal data of individuals who register for and use the jmmm platform.

This Policy applies to all personal data collected through the jmmm website at jmmm.cam, through any associated mobile-optimized interfaces, through customer support interactions, and through any other touchpoint where a player or prospective player provides personal information to jmmm. By creating a jmmm account or continuing to use the jmmm platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

jmmm is committed to full compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission (NPC). Where applicable, jmmm also applies internationally recognized data protection standards to ensure that Filipino players receive the highest level of privacy protection available.

2Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, jmmm Casino is the personal information controller in respect of the personal data of players using the jmmm platform at jmmm.cam. As the personal information controller, jmmm determines the purposes for which and the means by which personal data is processed, and bears the obligations imposed on controllers under RA 10173 and its implementing regulations.

jmmm has designated a Data Protection Officer (DPO) responsible for overseeing data protection compliance across the organization, handling data subject rights requests, and serving as the primary point of contact with the National Privacy Commission. Contact details for jmmm's DPO are provided in Section 15 of this Policy.

3Personal Data We Collect

jmmm collects personal data across several categories, depending on the nature of your interaction with the platform. The following table summarizes the categories of personal data collected and the primary source of that data:

3.1 Sensitive Personal Information

Certain personal data collected by jmmm during the KYC verification process — specifically government-issued identification documents — may constitute sensitive personal information as defined under RA 10173. jmmm applies heightened data security controls to sensitive personal information and processes it only for the strictly necessary purposes of age verification, identity verification, and anti-money laundering compliance. Sensitive personal information is not processed for any commercial purpose.

3.2 Data You Are Not Required to Provide

jmmm will clearly indicate at the point of data collection which fields are mandatory and which are optional. Providing optional data is entirely your choice and will not affect your ability to access core jmmm services. Declining to provide mandatory data may result in jmmm being unable to create or maintain your account or process withdrawal requests.

4Purposes of Processing

jmmm processes personal data for the following defined purposes. We do not process your data for any purpose incompatible with those stated below without first obtaining your explicit consent or as otherwise required by applicable law:

• Account Creation and Management: To register your jmmm account, maintain account records, authenticate your identity at login, and deliver the full range of platform services to you as a registered player.
• Payment Processing: To process deposits via GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency; to execute withdrawal requests; and to maintain accurate financial records of all transactions on your account.
• KYC and Regulatory Compliance: To verify your identity and age as required by applicable gaming and anti-money laundering regulations; to maintain KYC records as required by law; and to report suspicious financial activity to relevant Philippine regulatory authorities where legally obligated to do so.
• Responsible Gaming: To monitor gaming activity for patterns indicative of problem gambling; to administer player-activated tools such as deposit limits, session reminders, and self-exclusion; and to protect vulnerable players in accordance with responsible gaming obligations.
• Customer Support: To respond to your enquiries, complaints, and support requests; to investigate disputes; and to maintain records of communications for quality assurance and training purposes.
• Platform Security and Fraud Prevention: To detect, investigate, and prevent unauthorized account access, bonus abuse, collusion, money laundering, and other fraudulent or prohibited conduct on the platform.
• Platform Improvement: To analyze aggregate usage data and gaming patterns to improve the jmmm platform, fix technical issues, and develop new features — using anonymized or pseudonymized data wherever possible.
• Marketing Communications: To send you promotional offers, bonus notifications, and jmmm news where you have consented to receive such communications. You may withdraw marketing consent at any time through your account settings or by contacting jmmm support.
• Legal Obligations: To fulfil any legal obligation imposed on jmmm by applicable Philippine law, court order, regulatory directive, or lawful authority request.

5Legal Basis for Processing

jmmm processes personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its implementing regulations:

• Consent: Where you have provided clear, informed, and voluntary consent to a specific processing activity — for example, opting in to marketing communications or permitting jmmm to share your data with a specific third party not otherwise covered by this Policy.
• Contractual Necessity: Where processing is necessary to perform the contract between jmmm and you as a registered player — including account management, payment processing, and delivery of gaming services.
• Compliance with a Legal Obligation: Where processing is required to comply with a legal obligation applicable to jmmm, such as KYC record-keeping, anti-money laundering reporting, or regulatory audit requirements.
• Legitimate Interests: Where processing is necessary for jmmm's legitimate interests — including platform security, fraud detection, and aggregate analytics — provided that such interests are not overridden by your fundamental rights and freedoms as a data subject.

6Data Sharing and Disclosure

6.1 Categories of Recipients

jmmm does not sell your personal data to any third party. We may share your personal data with the following categories of recipients, strictly within the scope necessary for the stated purpose:

• Payment Service Providers: GCash (G-Xchange, Inc.), PayMaya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, and cryptocurrency payment processors — for the purpose of processing deposits and withdrawals to and from your jmmm account.
• KYC and Identity Verification Partners: Third-party identity verification service providers engaged to assist jmmm in fulfilling its KYC and age verification obligations. These partners are bound by strict data processing agreements and may not use your data for any purpose beyond verification.
• Game Software Providers: Third-party game developers and live dealer studio operators whose games are available on the jmmm platform. These providers may receive minimum necessary data (such as your account identifier and session data) to deliver game functionality.
• IT Infrastructure and Security Providers: Cloud hosting, content delivery, cybersecurity monitoring, and fraud detection service providers who support the operation and security of the jmmm platform.
• Customer Support Platforms: Third-party live chat and ticketing platforms that facilitate jmmm's customer support operations. Communication data is processed on these platforms under data processing agreements.
• Regulatory and Law Enforcement Authorities: Philippine gaming regulators, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, courts, and law enforcement agencies where jmmm is legally required or compelled to disclose personal data.

6.2 Business Transfers

In the event that jmmm undergoes a merger, acquisition, restructuring, or sale of all or part of its business assets, player personal data may be transferred as part of that transaction. In such circumstances, jmmm will endeavor to provide advance notice through a prominent platform notification and will ensure that the receiving entity is bound by privacy commitments at least equivalent to those set out in this Policy.

7International Data Transfers

Some of jmmm's third-party service providers — including cloud infrastructure providers and game platform operators — operate from servers located outside the Philippines. Where personal data is transferred internationally, jmmm ensures that such transfers are conducted in compliance with the Data Privacy Act of 2012 and subject to appropriate safeguards, including:

• Standard contractual clauses that impose data protection obligations on the recipient equivalent to those applicable in the Philippines;
• Transfer to jurisdictions recognized by the National Privacy Commission as providing an adequate level of data protection; or
• Any other lawful mechanism for international transfer recognized under RA 10173 and its implementing regulations.

You may request further information about the specific safeguards applied to international transfers of your personal data by contacting jmmm's Data Protection Officer at the contact details provided in Section 15.

8Data Retention

jmmm retains personal data only for as long as necessary to fulfil the specific purpose for which it was collected, or as required by applicable law. The following retention principles apply:

• Active Account Data: Personal data associated with an active jmmm account is retained for the lifetime of the account and for a period of five (5) years following account closure, to satisfy regulatory record-keeping requirements and to facilitate the resolution of any disputes arising after closure.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following the end of the business relationship, in compliance with anti-money laundering record-keeping obligations under Philippine law.
• Financial Transaction Records: Deposit and withdrawal transaction records are retained for a minimum of five (5) years in compliance with applicable financial record-keeping regulations.
• Customer Support Communications: Support interaction records are retained for a period of two (2) years from the date of the last communication, unless the subject matter requires longer retention for legal or dispute resolution purposes.
• Marketing Consent Records: Records of marketing consent are retained for the duration of the active consent and for a period of three (3) years following withdrawal of consent, to demonstrate compliance.
• Anonymized Analytics Data: Aggregated, anonymized usage and analytics data that cannot be attributed to any individual player may be retained indefinitely for platform improvement purposes.

Upon expiry of the applicable retention period, personal data is securely and irreversibly deleted or anonymized in a manner that prevents re-identification.

9Data Security

jmmm implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Encryption in Transit: All data transmitted between your device and jmmm's servers is encrypted using TLS 1.2 or higher with 256-bit cipher suites. This applies to all login sessions, payment transactions, and KYC document uploads.
• Encryption at Rest: Stored personal data — including KYC documents and payment credentials — is encrypted using AES-256 encryption on jmmm's server infrastructure.
• Access Controls: Access to personal data within jmmm's internal systems is granted on a strictly need-to-know basis, with role-based access controls, multi-factor authentication for privileged accounts, and comprehensive audit logging of all data access events.
• Security Monitoring: jmmm's infrastructure is monitored continuously for unauthorized access attempts, anomalous activity, and potential security incidents using automated intrusion detection systems.
• Penetration Testing: jmmm engages independent security professionals to conduct regular penetration testing and security audits of the platform's infrastructure and application security posture.
• Staff Training: All jmmm staff who handle personal data receive regular training on data protection obligations, privacy best practices, and security awareness.
• Incident Response: jmmm maintains a documented personal data breach response procedure. In the event of a personal data breach that is likely to result in harm to affected players, jmmm will notify the National Privacy Commission and affected players within the timeframes required by RA 10173.

10Cookies and Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit jmmm.cam. They enable jmmm to recognize your device, maintain your login session, remember your preferences, and collect aggregate analytics data about how players interact with the platform. jmmm also uses related tracking technologies including web beacons, pixel tags, and local storage.

10.2 Types of Cookies Used

• Strictly Necessary Cookies: These cookies are essential for the jmmm platform to function. They maintain your login session, preserve your security tokens, and enable core platform features. These cookies cannot be disabled without preventing you from using the platform.
• Performance and Analytics Cookies: These cookies collect anonymized information about how players navigate and use the jmmm platform — which pages are visited most frequently, how long sessions last, and where players encounter errors. This data is used to improve the platform experience.
• Functionality Cookies: These cookies remember your preferences — such as language settings, preferred deposit method, and responsible gaming configurations — so that you don't have to re-enter them on each visit.
• Security Cookies: These cookies support jmmm's fraud detection and bot prevention systems by helping distinguish legitimate player activity from automated or malicious behavior.

10.3 Managing Cookies

You may control non-essential cookies through your browser's cookie settings or through the cookie preference center available on jmmm.cam. Please note that disabling certain cookies may affect the functionality of the platform, including your ability to maintain a login session. Strictly necessary cookies cannot be disabled through preference settings as they are required for basic platform operation.

11Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you hold the following legally recognized rights in respect of your personal data held by jmmm. jmmm is committed to facilitating the exercise of these rights promptly and without unnecessary obstacle:

11.1 Exercising Your Rights

To exercise any of the rights described above, please contact jmmm's Data Protection Officer using the contact details provided in Section 15. jmmm will acknowledge your request within three (3) business days and will respond substantively within thirty (30) calendar days, or within the timeframe required by applicable law where that is shorter. In complex cases, jmmm may extend this period by an additional thirty (30) days, with advance notice and explanation provided to you.

jmmm may request verification of your identity before processing a data subject rights request to ensure that personal data is not disclosed to or acted upon at the request of an unauthorized party.

12Minors and Age Restriction

jmmm's platform and Services are strictly intended for individuals aged 21 years and above. jmmm does not knowingly collect personal data from individuals under 21 years of age. The registration process includes an age declaration and is subject to KYC verification that confirms the Player's date of birth against government-issued identification.

If jmmm becomes aware that personal data has been collected from an individual under the age of 21, it will take immediate steps to close the associated account, reverse any transactions, and securely delete the minor's personal data without unnecessary delay. Parents or guardians who believe that a minor has registered with jmmm should contact our Data Protection Officer immediately using the details in Section 15.

13Third-Party Links and Services

The jmmm platform may contain links to third-party websites, applications, or services — for example, links to game provider demonstration sites or payment provider help pages. jmmm does not control the content, privacy practices, or data processing activities of any third-party site. Visiting a third-party site from a link on jmmm is subject to that site's own privacy policy, which jmmm has no responsibility for and makes no representation about.

jmmm recommends that you review the privacy policy of any third-party website you visit via a link from the jmmm platform before providing any personal information to that site.

14Changes to This Privacy Policy

jmmm reserves the right to update, revise, or replace this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, platform features, or regulatory requirements. The "Effective Date" at the top of this Policy indicates the date on which the current version took effect.

Where changes to this Policy are material — meaning they significantly affect how your personal data is processed or your rights as a data subject — jmmm will provide advance notice of at least fourteen (14) days via your registered email address and through a prominent notice on the jmmm platform. Your continued use of the jmmm platform after the effective date of a revised Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you may request account closure as described in jmmm's Terms & Conditions.

For non-material changes — such as clarifications of existing language, corrections of typographical errors, or updates to contact information — jmmm may update this Policy without prior notice, though the Effective Date will be updated to reflect the change.

15Contact Us & Data Protection Officer

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by jmmm, please contact us through the following channels. jmmm's Data Protection Officer is the designated point of contact for all data privacy matters:

• Email (General Support): [email protected]
• Email (Data Privacy / DPO): [email protected]
• Live Chat: Available 24/7 within your jmmm account dashboard after login
• Response Time: Data subject rights requests are acknowledged within 3 business days and resolved within 30 calendar days

If you are not satisfied with jmmm's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. Details of how to contact the NPC are available on the NPC's official website.