jwhub Privacy Policy – Your Data, Protected

1. Overview & Scope

This Privacy Policy applies to all personal information collected, used, stored, and disclosed by jwhub ("jwhub," "we," "us," or "our") in connection with the online gaming platform accessible at jwhub.cam and all related mobile or web interfaces (collectively, the "Platform").

This Policy applies to all current and former registered players, visitors to the Platform, and any individual whose personal information jwhub processes in the course of operating the Platform. It covers data processed in relation to account registration, identity verification, gaming activity, financial transactions, marketing communications, customer support interactions, and website usage.

This Privacy Policy should be read together with jwhub's Terms & Conditions, which contain additional provisions relevant to your use of the Platform.

2. Data Controller

jwhub is the Personal Information Controller (PIC) in respect of all personal data collected through and in connection with the Platform. As PIC, jwhub determines the purposes and means of processing your personal information and is responsible for ensuring that processing is carried out lawfully, fairly, and transparently.

jwhub has designated a Data Protection Officer (DPO) in accordance with Section 21 of the Data Privacy Act. The DPO is responsible for overseeing jwhub's data protection compliance, handling data subject requests, and serving as the point of contact with the National Privacy Commission.

You may contact jwhub's DPO at any time for privacy-related matters using the contact details in Section 15 of this Policy.

3. Personal Data We Collect

jwhub collects personal information that is necessary to provide its gaming services, comply with legal obligations, and maintain the security of the Platform. The categories of personal data we collect include:

jwhub does not intentionally collect special categories of sensitive personal information (as defined under the Data Privacy Act) such as health data, religious beliefs, or political affiliations, unless required by a specific legal or regulatory obligation.

4. How We Collect Personal Data

jwhub collects personal information through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, participating in promotions, or updating your account settings.
• Automated collection: Technical data collected automatically when you access or use the Platform, including through cookies, web beacons, server logs, and similar tracking technologies as described in Section 10.
• Third-party sources: Identity verification data from document verification service providers; financial data from payment processors including GCash, Maya, and partner banks; fraud prevention data from third-party risk management services; and regulatory data from PAGCOR and relevant government databases where permitted by law.
• Publicly available sources: Information available in public registries where relevant to fulfilling jwhub's legal and regulatory obligations.

5. Purposes of Processing

jwhub processes your personal information for the following purposes:

• Account registration and management: Creating and maintaining your jwhub account, verifying your identity, and managing your account settings and preferences.
• Service delivery: Enabling you to access and use all jwhub gaming products including sports betting, live casino, slots, bingo, and promotions.
• Financial transactions: Processing deposits, withdrawals, and refunds via GCash, Maya, PayMaya, BPI, BDO, Metrobank, InstaPay, PesoNet, and other supported payment methods.
• Regulatory compliance: Fulfilling jwhub's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws and regulations, including reporting to PAGCOR and the Anti-Money Laundering Council (AMLC) where required.
• Identity verification and fraud prevention: Verifying player identity, detecting and preventing fraud, money laundering, bonus abuse, and other prohibited conduct as described in the Terms & Conditions.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior, implementing player-requested responsible gaming tools such as deposit limits and self-exclusion, and complying with PAGCOR's Responsible Gaming Framework.
• Customer support: Responding to your inquiries, resolving disputes, and improving the quality of jwhub's support services.
• Platform improvement and analytics: Analyzing usage patterns to improve Platform functionality, game selection, and user experience. Where used for analytics, data is aggregated or pseudonymized to the greatest extent possible.
• Marketing communications: Sending you information about jwhub promotions, bonuses, and new features where you have opted in to receive such communications. You may opt out at any time as described in Section 12.
• Security: Protecting the integrity and security of the Platform, detecting unauthorized access, and investigating suspicious activity.

6. Legal Basis for Processing

Under the Data Privacy Act, jwhub processes personal information based on one or more of the following lawful bases:

• Contractual necessity: Processing required to perform our obligations under the jwhub Terms & Conditions, including account management, service delivery, and financial transactions.
• Legal obligation: Processing required to comply with mandatory requirements under PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act, PAGCOR's Responsible Gaming Framework, and other applicable Philippine laws.
• Legitimate interest: Processing necessary for jwhub's legitimate interests in fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and interests.
• Consent: Processing for marketing communications and certain optional features, where you have given your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

7. Sharing Personal Data

jwhub does not sell your personal data. We may share personal information with the following categories of recipients for the purposes described in Section 5:

• Payment processors: GCash, Maya, and partner bank and fintech payment processors to facilitate deposits and withdrawals. These processors act as separate personal information controllers in respect of the data they collect through their own platforms.
• Identity verification providers: Third-party KYC and document verification service providers who process your identity documents and verification data on jwhub's behalf as Personal Information Processors (PIPs).
• Technology and infrastructure providers: Cloud hosting, data storage, cybersecurity, and analytics service providers operating under data processing agreements that impose obligations consistent with the Data Privacy Act.
• Game content providers: Third-party game software providers who may receive game session data necessary to deliver their game content and calculate payouts. These providers operate under contractual obligations limiting their use of such data.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies, where disclosure is required by law, court order, or regulatory directive.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers bound by confidentiality obligations, where necessary in the context of legal proceedings, audits, or regulatory reviews.

8. Data Retention

jwhub retains personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce agreements. The following general retention periods apply:

• Account and KYC data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing conditions and AMLC record-keeping requirements under the Anti-Money Laundering Act.
• 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 PAGCOR regulations.
• Gaming activity logs: Retained for three (3) years from the date of each session, unless required to be kept longer for dispute resolution or regulatory purposes.
• Customer support records: Retained for two (2) years from the date of the last interaction, unless the subject matter relates to a pending dispute or legal proceeding.
• Marketing data: Retained until you opt out of marketing communications, at which point marketing preference data is updated but retained as a record of your opt-out to prevent accidental re-enrollment.
• Technical and log data: Retained for up to twelve (12) months for security and analytical purposes, after which it is deleted or anonymized.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized.

9. Security Measures

jwhub implements appropriate technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jwhub's servers;
• Encryption of sensitive data at rest, including password hashes and financial credentials;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication requirements for all staff accessing systems containing personal data;
• Regular security vulnerability assessments and penetration testing by independent security firms;
• Intrusion detection systems and 24/7 security monitoring;
• Data breach incident response procedures tested at least annually;
• Regular staff training on data protection obligations and security practices.

While jwhub takes all reasonable and required steps to protect your personal data, no transmission over the internet or electronic storage system is completely secure. You also play a role in protecting your account by using a strong, unique password and enabling two-factor authentication.

10. Cookies & Tracking Technologies

jwhub uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file stored on your device when you access a website. jwhub uses the following categories of cookies:

Essential Analytics Functional

• Essential cookies Required: Necessary for the Platform to function. These include session authentication cookies, security tokens, and cookies that maintain your login state. These cannot be disabled without breaking core Platform functionality.
• Functional cookies Optional: Remember your preferences such as language settings, preferred payment method, and responsible gaming tool configurations. Disabling these may reduce convenience.
• Analytics cookies Optional: Collect aggregated and pseudonymized data about how the Platform is used to help us improve performance, page load times, and user experience. jwhub uses self-hosted analytics tools where possible to minimize data sharing.

You can manage your cookie preferences through your browser settings. Blocking essential cookies will prevent you from logging in to jwhub. For instructions on managing cookies in your specific browser, refer to your browser's help documentation.

11. Minors' Privacy

jwhub is strictly an adult gaming platform. In accordance with PAGCOR regulations, the minimum age for registration and participation is twenty-one (21) years. jwhub does not knowingly collect personal information from individuals below this age.

If you are under 21 years of age, you must not register on or use jwhub. If jwhub discovers or has reasonable grounds to believe that a registered account belongs to a person under 21, the account will be immediately closed, the matter will be reported to PAGCOR, and any balance may be handled in accordance with applicable regulatory guidance.

If you are a parent or guardian and believe that your child under 21 has provided personal information to jwhub or registered an account, please contact jwhub immediately at [email protected] so that appropriate action can be taken.

12. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by jwhub. To exercise any of these rights, please contact jwhub's Data Protection Officer using the details in Section 15. jwhub will respond to your request within fifteen (15) calendar days, or within a longer period where permitted by the NPC for complex requests.

To exercise your rights, please submit a written request to jwhub's DPO at [email protected] with the subject line "Data Subject Rights Request." We may need to verify your identity before processing your request. Identity verification for data subject requests is performed via your registered Philippine mobile number or government-issued ID, and does not require an in-person visit.

13. Cross-Border Data Transfers

jwhub's primary data processing infrastructure is located within the Philippines. However, some service providers used by jwhub – including certain game content providers, cloud infrastructure providers, and identity verification services – may process data in other countries.

Where personal data is transferred outside the Philippines, jwhub ensures that appropriate safeguards are in place as required by the Data Privacy Act and NPC regulations, including:

• Executing standard contractual clauses or equivalent data transfer agreements with receiving entities;
• Transferring only to countries or entities that provide an adequate level of protection as recognized by the NPC;
• Obtaining your consent where required for specific transfers not covered by the above mechanisms.

jwhub does not transfer personal data to jurisdictions that do not provide adequate protection under Philippine data privacy standards without implementing appropriate contractual or technical safeguards.

14. Amendments to This Policy

jwhub reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The "Last Updated" date at the top of this document will be revised accordingly.

Where amendments are material – meaning they significantly affect your rights or how your personal data is processed – jwhub will notify you via email or SMS to your registered contact details at least fourteen (14) days before the amendments take effect. Non-material clarifications may take effect upon publication.

Continued use of jwhub following the effective date of a revised Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with a material amendment, you may close your account before the effective date in accordance with jwhub's account closure process described in the Terms & Conditions.

15. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or jwhub's data processing practices, you may contact jwhub's Data Protection Officer through the following channels:

• Email (DPO & Privacy Requests): [email protected] — please use the subject line "Privacy Policy Inquiry" or "Data Subject Rights Request."
• General Support (Live Chat): Available 24/7 via the live chat widget accessible on all jwhub pages.
• Language: Privacy-related correspondence is handled in English and Filipino (Tagalog). Response time is within two (2) business days for privacy matters.