Privacy Policy

1. Introduction

1.1 smjl Casino is an online gaming platform operated under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR), serving Filipino players across the Philippines — from Manila and Makati to Cebu, Davao, and Quezon City.

1.2 We understand that your personal data is important to you. This Privacy Policy explains in plain terms what information we collect when you use smjl, why we need it, how we protect it, and what control you have over it.

1.3 This policy applies to all personal data collected through smjl.club, including data collected during account registration, smjl login, deposits, withdrawals, gameplay, customer support interactions, and any other use of our services.

1.4 This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy.

2. Personal Data We Collect

2.1 Registration Data

When you create a smjl account, we collect: full legal name, date of birth, residential address, email address, mobile number, and chosen username. This information is required to open and maintain your account.

2.2 Identity Verification (KYC) Data

To comply with PAGCOR anti-money laundering requirements and to verify that you meet the 21+ age requirement, we may collect copies of government-issued identification (e.g., Philippine passport, SSS ID, driver's licence, PhilSys national ID), proof of address, and proof of payment method.

2.3 Financial Data

We collect information necessary to process deposits and withdrawals, including GCash account details, PayMaya / Maya account details, and Philippine bank account information (BPI, BDO, Metrobank, UnionBank, and other major PH banks). We do not store full payment credentials on our servers — payment processing is handled by regulated payment service providers.

2.4 Transaction Data

We maintain records of all deposits, withdrawals, bonus claims, and gameplay transactions associated with your smjl account. These records are required for regulatory compliance and dispute resolution.

2.5 Technical Data

When you access smjl.club, we automatically collect: IP address, browser type and version, device type and operating system, referring URL, pages visited, session duration, and cookie identifiers. This data helps us maintain platform security and improve user experience.

2.6 Communications Data

If you contact smjl Casino support, we retain records of your communications, including emails, live chat transcripts, and any documents you submit, for quality assurance and dispute resolution purposes.

3. How We Use Your Personal Data

smjl Casino uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your smjl account and smjl login credentials;
• Identity verification: Confirming your age (21+) and identity in compliance with PAGCOR KYC requirements;
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers in PHP;
• Regulatory compliance: Meeting our obligations under PAGCOR regulations, the Data Privacy Act of 2012, and anti-money laundering laws;
• Fraud prevention: Detecting and preventing fraudulent activity, money laundering, and abuse of the smjl platform;
• Customer support: Responding to your enquiries, resolving disputes, and providing technical assistance;
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behaviour and applying responsible gaming tools where appropriate;
• Platform improvement: Analysing usage data to improve smjl Casino's games, features, and overall player experience;
• Marketing communications: Sending you promotional offers, bonus notifications, and updates about smjl — only where you have given your consent to receive such communications.

4. Legal Basis for Processing

4.1 smjl Casino processes your personal data on the following legal bases under the Data Privacy Act of 2012 (Republic Act No. 10173):

• Contractual necessity: Processing required to fulfil our obligations under the smjl Terms & Conditions, including account management and payment processing;
• Legal obligation: Processing required to comply with PAGCOR regulations, anti-money laundering laws, and other applicable Philippine legislation;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring;
• Consent: Processing for marketing communications, where you have explicitly opted in to receive such communications from smjl.

4.2 Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time by contacting our support team or updating your account preferences.

5. Data Sharing & Disclosure

5.1 smjl Casino does not sell, rent, or trade your personal data to third-party marketers under any circumstances.

5.2 We may share your personal data with the following categories of third parties, strictly on a need-to-know basis:

• Payment service providers: GCash, PayMaya, and Philippine banking partners, for the purpose of processing deposits and withdrawals;
• Identity verification providers: Third-party KYC service providers engaged to verify player identity and age;
• Regulatory authorities: PAGCOR and other Philippine government agencies, where disclosure is required by law or regulatory obligation;
• Fraud prevention services: Third-party providers engaged to detect and prevent fraudulent activity on the smjl platform;
• IT and hosting providers: Service providers who host and maintain the smjl.club platform infrastructure, subject to strict data processing agreements;
• Professional advisers: Legal, accounting, and auditing firms where disclosure is necessary for the conduct of their professional services.

5.3 All third parties with whom smjl shares personal data are required to handle that data in accordance with applicable Philippine data protection law and are prohibited from using it for any purpose other than the specific service they provide to smjl.

5.4 smjl may disclose your personal data where required to do so by law, court order, or the lawful request of a competent Philippine government authority.

6. Cookies & Tracking Technologies

6.1 smjl.club uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse site usage. A cookie is a small text file stored on your device when you visit a website.

6.2 We use the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function, including maintaining your smjl login session and processing transactions. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options to personalise your smjl experience.
• Analytics cookies: Collect anonymised data about how players use smjl.club, helping us identify areas for improvement. No personally identifiable information is included in analytics data.
• Security cookies: Used to detect and prevent fraudulent activity and protect the integrity of the smjl platform.

6.3 You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of smjl.club. Strictly necessary and security cookies cannot be disabled without impacting your ability to use the platform.

7. Data Retention

7.1 smjl Casino retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and PAGCOR regulations.

7.2 Specifically:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Communications data: Retained for three (3) years from the date of the communication, or longer where relevant to an ongoing dispute;
• Technical and analytics data: Retained in anonymised or aggregated form for up to two (2) years.

7.3 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with smjl's data disposal procedures.

8. Data Security

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

• SSL/TLS encryption for all data transmitted between your device and smjl.club;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security audits and vulnerability assessments of the smjl platform;
• Multi-factor authentication requirements for administrative access to smjl systems;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, smjl will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.

8.3 While smjl takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your smjl login credentials confidential and for notifying us immediately if you suspect any unauthorised access to your account.

9. Your Data Privacy Rights

9.1 Under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by smjl Casino:

• Right to be informed: The right to know what personal data smjl collects about you and how it is used;
• Right of access: The right to request a copy of the personal data smjl holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to legal and regulatory retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

9.2 To exercise any of the above rights, please contact our Data Protection Officer at the email address listed in Section 12. We will respond to all verified requests within thirty (30) calendar days.

9.3 Please note that certain rights may be limited where smjl is required to retain or process your data to comply with PAGCOR regulations or other applicable Philippine law.

10. Children's Privacy

10.1 smjl Casino is strictly for players aged 21 years and above. We do not knowingly collect personal data from persons under the age of 21.

10.2 If we become aware that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, forfeit any balance, and delete the personal data in question.

10.3 If you believe that a minor has registered on smjl Casino, please contact us immediately at [email protected] so that we can take appropriate action.

11. Changes to This Privacy Policy

11.1 smjl Casino reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements.

11.2 Where changes are material, we will notify registered players via the email address on file and post a prominent notice on smjl.club. The "Last updated" date at the top of this policy will always reflect the most recent revision.

11.3 Your continued use of smjl.club following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to the updated policy, you must cease using smjl Casino and may request account closure.

12. Contact & Data Protection Officer

12.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by smjl Casino, please contact our Data Protection Officer:

• Email: [email protected]
• Subject line: Data Privacy Request – [Your Full Name]
• Response time: Within 30 calendar days of receipt

12.2 If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).