jwhub Privacy Policy

This Privacy Policy applies to all personal data processed by jwhub in connection with the operation of its online gaming platform, including the jwhub website, mobile-optimised interface, and any associated applications or services made available to players in the Philippines and other permitted jurisdictions.

jwhub is committed to protecting the personal data of all Filipino players — whether you are accessing jwhub from Manila, Cebu, Davao, Quezon City, Makati, or anywhere else in the Philippines — in full accordance with Republic Act No. 10173 (the Data Privacy Act of 2012, "DPA"), its Implementing Rules and Regulations ("IRR"), and all applicable circulars and issuances of the National Privacy Commission ("NPC") of the Philippines.

This Policy is written in plain, accessible English so that every jwhub player understands exactly how their data is handled. If you have questions after reading this Policy, you are encouraged to contact our Data Protection Officer (DPO) using the details in Section 15.

jwhub is an online gaming and sports betting platform operating under applicable PAGCOR regulatory requirements, serving players in the Philippines. In the context of this Privacy Policy, jwhub acts as the personal information controller in respect of the personal data of registered players, prospective players, and website visitors, as those terms are defined under the Philippine Data Privacy Act of 2012.

As a personal information controller, jwhub determines the purposes for which and the means by which your personal data is processed. jwhub engages certain third-party service providers who act as personal information processors on jwhub's behalf — these arrangements are described in Section 7 of this Policy.

jwhub collects only the personal data necessary to operate its platform, comply with legal obligations, and deliver a secure and personalised experience to Filipino players. The categories of personal data we collect are described in the table below:

jwhub collects personal data through several channels, all of which are disclosed here in the interest of full transparency:

• Direct Submission: Data you provide when creating a jwhub account, completing KYC verification, making deposits or withdrawal requests, contacting jwhub support, completing responsible gaming forms, or updating your account profile;
• Automated Technical Collection: When you access the jwhub platform, our servers automatically record technical data including your IP address, device identifiers, browser type, session duration, and pages visited. This collection is necessary to operate the platform and to detect fraud and unauthorised access;
• Cookies and Tracking Technologies: jwhub uses cookies and similar technologies as described in Section 8 of this Policy. These may be set by jwhub directly or by authorised third-party service providers;
• Payment Processors: When you transact via GCash, Maya, BPI, BDO, or other supported payment channels, jwhub receives transaction confirmation data from those processors sufficient to credit your jwhub wallet and maintain financial records;
• Identity Verification Providers: jwhub may engage third-party KYC and identity verification providers who process identity document images and biometric comparisons on jwhub's behalf in order to verify your identity;
• Third-Party Game Providers: Game providers integrated into the jwhub platform (including JILI and live dealer studio operators) may share session data and bet records with jwhub for reconciliation and player protection purposes.

jwhub processes your personal data only for specified, explicit, and legitimate purposes. The primary purposes for which jwhub processes player data are as follows:

• Account Creation and Management: To register your jwhub account, authenticate your identity at login, and maintain your account in active and accurate condition;
• KYC and Identity Verification: To verify that you meet the eligibility requirements to use jwhub, including the mandatory 21+ age requirement, in accordance with PAGCOR regulations and jwhub's platform policies;
• Payment Processing: To process your deposit and withdrawal transactions through GCash, Maya, and other supported Philippine payment channels, and to maintain the financial records required by law;
• AMLA Compliance: To meet jwhub's obligations under the Anti-Money Laundering Act (Republic Act No. 9160, as amended) and its implementing regulations, including customer due diligence, transaction monitoring, and Suspicious Transaction Reporting (STR) obligations;
• PAGCOR Regulatory Compliance: To fulfil all reporting, record-keeping, and player protection requirements imposed by jwhub's gaming regulatory framework;
• Customer Support: To respond to your queries, resolve disputes, process complaints, and deliver player support via live chat and email;
• Responsible Gaming: To administer deposit limits, loss limits, self-exclusion requests, and other responsible gaming tools; to monitor for indicators of problem gambling behaviour; and to proactively contact players where welfare concerns are identified;
• Fraud Prevention and Platform Security: To detect, investigate, and prevent fraudulent transactions, multi-accounting, collusion, money laundering, and any other conduct that threatens platform integrity or other players;
• VIP Program and Promotions: To administer the jwhub Black Diamond VIP loyalty program, calculate tier status and cashback, and deliver promotional communications to eligible players who have provided marketing consent;
• Platform Improvement: To analyse anonymised or aggregated usage data for the purpose of improving jwhub's games, features, and user experience — this analysis does not use individually identifiable data.

Under the Philippine Data Privacy Act of 2012, jwhub must have a lawful basis for each category of personal data processing. The legal bases jwhub relies upon are as follows:

• Contractual Necessity: Processing required to perform the contract between you and jwhub — including account creation, payment processing, game delivery, and VIP program administration — is carried out on the basis that it is necessary to fulfil our contractual obligations to you;
• Legal Obligation: Processing required to comply with jwhub's obligations under Philippine law — including AMLA compliance, PAGCOR regulatory reporting, age verification, and tax record-keeping — is carried out on the basis of legal obligation;
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and anonymised analytics is carried out on the basis of jwhub's legitimate interests, where those interests are not overridden by your rights and interests;
• Consent: Processing for marketing communications (promotional emails, SMS, push notifications) is carried out on the basis of your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting your account status.

jwhub does not sell, rent, or trade your personal data to any third party for their own commercial purposes. jwhub shares personal data only in the following limited and controlled circumstances:

• Regulatory Authorities: jwhub shares player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where legally required or in response to a valid legal order;
• Payment Service Providers: Transaction data is shared with GCash, Maya, BPI, BDO, Metrobank, and other payment processors to the extent required to process your deposits and withdrawals. These providers are bound by their own privacy and data security obligations;
• KYC and Identity Verification Providers: Identity document images and verification data are shared with authorised KYC providers solely for the purpose of verifying your identity. These providers act as personal information processors under jwhub's instructions and are bound by data processing agreements;
• Game Technology Providers: Bet and session data is shared with integrated game providers (such as JILI and live dealer operators) for the purpose of delivering game content, resolving game disputes, and maintaining RNG audit records;
• IT Infrastructure and Security Providers: jwhub uses cloud hosting, content delivery, and cybersecurity providers who process technical data on jwhub's behalf under binding data processing agreements and strict confidentiality obligations;
• Professional Advisors: jwhub may share data with its legal counsel, auditors, and compliance consultants where strictly necessary for the provision of professional services, subject to professional confidentiality obligations.

jwhub uses cookies and similar tracking technologies (including session tokens, pixel tags, and local storage objects) to operate the platform, ensure security, and improve player experience. The types of cookies used by jwhub are as follows:

• Strictly Necessary Cookies: These cookies are essential for the jwhub platform to function. They enable your jwhub login session to persist, protect against cross-site request forgery (CSRF), and ensure the security of your account. These cookies cannot be disabled without disrupting platform functionality;
• Functional Cookies: These cookies remember your preferences — such as your preferred language setting, display preferences, and responsible gaming reminder settings — to provide a personalised experience across sessions;
• Analytics Cookies: jwhub uses anonymised analytics cookies to understand how players navigate the platform, which games are most popular, and where technical issues arise. This data is aggregated and does not identify individual players;
• Security Cookies: These cookies support jwhub's fraud detection and bot prevention systems by tracking device fingerprints and session behaviour patterns for anomaly detection purposes.

You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect your ability to log in and use core platform features. jwhub does not use third-party advertising or retargeting cookies.

jwhub retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law. The key retention periods applied by jwhub are as follows:

• Account and Identity Data: Retained for the duration of your jwhub account plus a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act and its implementing regulations;
• KYC Document Images: Retained for a minimum of five (5) years from the date of verification, or longer where required by a regulatory hold or investigation;
• Gaming Activity Logs: Retained for a minimum of three (3) years for dispute resolution and regulatory audit purposes;
• Customer Support Communications: Retained for two (2) years from the date of the last interaction, to support dispute resolution and quality assurance;
• Marketing Consent Records: Retained for the duration of your account plus two (2) years, to evidence consent and opt-out records in the event of a regulatory query;
• Technical / Server Logs: Retained for twelve (12) months for security monitoring and fraud investigation purposes.

Upon expiry of the applicable retention period, jwhub will securely delete or irreversibly anonymise your personal data, unless a legal hold, regulatory investigation, or ongoing dispute requires continued retention.

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by jwhub. jwhub is committed to honouring all valid data subject rights requests within the timeframes prescribed by the NPC:

To exercise any of the above rights, please contact jwhub's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." Please include your full name, registered email address, and a description of your request. jwhub may require you to verify your identity before processing a data subject rights request.

jwhub implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key security measures include:

• TLS 1.3 Encryption in Transit: All data transmitted between your device and jwhub servers is encrypted using Transport Layer Security version 1.3;
• AES-256 Encryption at Rest: Sensitive data stored on jwhub infrastructure — including KYC documents, financial records, and account credentials — is encrypted at rest using AES-256 symmetric encryption;
• Credential Security: jwhub login passwords are stored exclusively as salted cryptographic hashes using industry-standard algorithms. Plain-text passwords are never stored;
• Access Controls: Access to player personal data is restricted on a strict need-to-know basis. jwhub staff access logs are maintained and reviewed regularly;
• Two-Factor Authentication: jwhub offers 2FA for player accounts and enforces 2FA for all internal staff systems with access to player data;
• Penetration Testing: jwhub conducts regular third-party penetration tests and vulnerability assessments of its platform infrastructure;
• Incident Response: jwhub maintains a documented data breach response procedure. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, jwhub will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where required by the DPA;
• Staff Training: All jwhub personnel with access to personal data undergo mandatory data privacy and security training upon onboarding and on an annual basis thereafter;
• Third-Party Processor Vetting: All third-party service providers who process personal data on jwhub's behalf are subject to due diligence assessments and are required to execute data processing agreements that impose security and confidentiality obligations consistent with the DPA.

jwhub is strictly an adults-only platform. In accordance with Philippine law and PAGCOR regulations, jwhub does not permit any person under 21 years of age to register an account, access gaming content, or make any financial transaction on the platform.

If you are a parent or guardian and believe that a minor in your care has registered a jwhub account or submitted personal data to jwhub, please contact our Data Protection Officer at [email protected] immediately with the subject line "Minor Account Report." jwhub will investigate and take appropriate action within one business day of receiving such a report.

jwhub's primary data processing infrastructure is operated in data centres within the Asia-Pacific region. In certain circumstances, personal data may be transferred to or accessed from locations outside the Philippines — for example, where jwhub engages a cloud infrastructure provider, KYC technology partner, or game studio that operates servers in another jurisdiction.

Where personal data is transferred outside the Philippines, jwhub ensures that an adequate level of protection applies to that data. The safeguards jwhub relies upon for cross-border transfers include:

• Contractual Safeguards: jwhub executes data processing agreements and standard contractual clauses with all international service providers, imposing data protection standards consistent with the Philippine DPA;
• Adequacy Assessments: Where jwhub transfers data to a jurisdiction assessed by the NPC as providing an adequate level of data protection, the transfer proceeds on that basis;
• Binding Corporate Rules: Where a service provider group has adopted Binding Corporate Rules (BCR) approved by a competent supervisory authority, jwhub may rely on those BCRs as a transfer safeguard.

You may request information about the specific safeguards applied to any cross-border transfer of your personal data by contacting jwhub's DPO at [email protected].

jwhub reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable Philippine law, NPC guidance, PAGCOR regulations, jwhub's business operations, or data processing practices. All amendments will be published on the jwhub website at /privacy-policy and will be effective from the date indicated at the top of the revised Policy.

Where an amendment materially affects your rights or the way in which jwhub processes your personal data, jwhub will provide advance notice to registered players via email to the address associated with your jwhub account, or via a prominent notice on the platform, at least fourteen (14) days prior to the effective date of the change.

Your continued use of the jwhub platform following the effective date of any amended Privacy Policy constitutes your acknowledgment of the updated Policy. If you do not agree with any amendment, you have the right to close your account and request erasure of your personal data in accordance with Section 10, subject to jwhub's mandatory legal retention obligations.

jwhub has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by jwhub, please contact the DPO using the details below:

• Data Protection Officer: jwhub Data Privacy Team
• Email: [email protected] — Subject line: "Data Privacy Request" or "DPO Enquiry"
• Support Hours: 24 hours a day, 7 days a week, including Philippine public holidays
• Response Target: Acknowledgment within 1 business day; full response within 15 business days for data subject rights requests

If you are not satisfied with jwhub's response to a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for administering and enforcing the Philippine Data Privacy Act of 2012.