Privacy Policy for 36jl.com

01 Introduction

36jl.com (accessible at 36jlcom.org) is committed to protecting the privacy and personal data of all players and visitors. This Privacy Policy describes how 36jl.com collects, uses, stores, shares, and protects personal data in connection with the operation of the platform, including its live casino, slot games, bingo, sports betting, and promotional services.

This Privacy Policy has been prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. Where applicable, it also reflects internationally recognised data protection principles.

We encourage you to read this Privacy Policy in full. If you have any questions about how 36jl.com handles your personal data, please contact our Data Protection Officer using the details provided in Section 15.

02 Data Controller

For the purposes of the Data Privacy Act of 2012, the data controller responsible for your personal data is 36jl.com, operating through the website 36jlcom.org. As data controller, 36jl.com determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data privacy laws.

36jl.com has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection legislation. You may contact the DPO at the email address provided in Section 15 of this Policy.

03 Personal Data We Collect

36jl.com collects the following categories of personal data from players and platform visitors:

3.1 Identity and Contact Data

• Full legal name
• Date of birth
• Gender
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Government-issued ID number (for K YC verification)

3.2 Financial Data

• GCash or PayMaya account number (mobile number)
• Bank account details (account name, account number, bank name) for withdrawal processing
• Deposit and withdrawal transaction history
• Account balance information

3.3 Gaming and Activity Data

• Game history, wager amounts, and outcomes
• Bonus and promotion usage history
• Session duration and login timestamps
• Responsible gaming tool settings (deposit limits, self-exclusion status)

3.4 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Cookie identifiers and session tokens
• Platform interaction logs and error reports

3.5 Communications Data

• Records of your communications with 36jl.com customer support (live chat transcripts, email correspondence)
• Survey responses and feedback submissions

04 How We Collect Your Data

36jl.com collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or participating in a promotion.
• Automated collection: Data collected automatically when you access and use the platform, including through cookies, web beacons, server logs, and similar tracking technologies (see Section 8).
• Third-party sources: Data received from identity verification providers, payment processors (such as GCash, PayMaya, and partner banks), fraud prevention services, and regulatory authorities where permitted by law.

05 How We Use Your Personal Data

36jl.com uses your personal data for the following purposes:

36jl.com will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

06 Legal Basis for Processing

Under the Data Privacy Act of 2012, 36jl.com processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML obligations under the Anti-Money Laundering Act (AMLA), age verification requirements, and reporting obligations to PAGCOR and the AMLC.
• Legitimate interests: Processing necessary for 36jl.com's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Sharing Your Personal Data

36jl.com does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, and partner Philippine banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with Philippine regulatory requirements.
• IT and platform service providers: Cloud hosting, cybersecurity, and technical support providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where disclosure is required by law or court order.
• Professional advisers: Lawyers, auditors, and accountants where necessary for legal, compliance, or financial purposes, subject to professional confidentiality obligations.

All third parties with whom 36jl.com shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and 36jl.com's data protection standards.

08 Cookies & Tracking Technologies

36jl.com uses cookies and similar tracking technologies to operate and improve the platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies: Used to collect anonymised data about how players use the platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 36jl.com platform. 36jl.com does not use cookies to track your activity across unrelated third-party websites.

09 Data Security

36jl.com implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 36jl.com servers.
• Encryption of sensitive data at rest, including financial and identity data.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Multi-factor authentication for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While 36jl.com takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying 36jl.com immediately if you suspect any unauthorised access to your account.

10 Data Retention

36jl.com retains your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AMLA record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and its implementing rules.
• Gaming and activity data: Retained for a minimum of three (3) years from the date of the relevant activity.
• Customer support communications: Retained for a minimum of two (2) years from the date of the communication.
• Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter as evidence of consent.

When personal data is no longer required for any lawful purpose, 36jl.com will securely delete or anonymise it in accordance with our data disposal procedures.

11 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 36jl.com:

• Right to be informed: The right to be informed of how your personal data is being collected and processed — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data 36jl.com holds about you and information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where processing is based on consent or contract.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that 36jl.com has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified requests within 15 business days. We may need to verify your identity before processing your request.

12 Children's Privacy

36jl.com is strictly intended for persons who are 21 years of age or older. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on 36jl.com or provided personal data to us, please contact our Data Protection Officer immediately using the details in Section 15.

13 International Data Transfers

36jl.com primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines (for example, cloud infrastructure providers or international KYC services), 36jl.com will ensure that such transfers are carried out in accordance with the Data Privacy Act of 2012 and applicable NPC guidelines.

International transfers of personal data will only be made to countries or organisations that provide an adequate level of data protection, or where appropriate safeguards are in place, such as contractual clauses approved by the NPC. 36jl.com will not transfer your personal data internationally in a manner that reduces your rights and protections under Philippine law.

14 Changes to This Privacy Policy

36jl.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform operations. Where changes are material, we will notify registered players via email or a prominent notice on the platform prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when the Privacy Policy was most recently revised. Your continued use of 36jl.com following the effective date of any revised Privacy Policy constitutes your acknowledgement of the changes. We encourage you to review this Privacy Policy periodically.

15 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 36jl.com handles your personal data, please contact our Data Protection Officer:

Data Protection Officer — 36jl.com
Email: [email protected]
General Support: [email protected]

We aim to respond to all data privacy enquiries within 15 business days. If you are not satisfied with our response, or if you believe that 36jl.com has violated your rights under the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.