jl36 Privacy Policy

01 Introduction

jl36 respects the privacy of all users and is committed to protecting personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission of the Philippines.

This Privacy Policy applies to all personal information collected through the jl36 Platform, including information collected when you:

• Visit or browse the jl36 website or mobile application;
• Register for a jl36 account;
• Make deposits or withdrawals;
• Participate in games, promotions, or tournaments;
• Contact our customer support team;
• Subscribe to marketing communications; or
• Otherwise interact with the Platform or our services.

This Policy should be read in conjunction with our Terms & Conditions, which govern your use of the jl36 Platform.

02 Information We Collect

jl36 collects the following categories of personal information from users:

2.1 Information You Provide Directly

• Account Registration Data: Full name, date of birth, email address, mobile phone number, residential address, and username.
• Identity Verification Data (KYC): Government-issued ID (e.g., PhilSys ID, passport, driver's license, UMID), proof of address (utility bill, bank statement), and selfie photographs for identity verification purposes.
• Financial Information: Payment method details (GCash number, PayMaya account, bank account information), transaction history, deposit and withdrawal records.
• Communications: Any information you provide when contacting customer support, including chat transcripts, emails, and support tickets.
• Marketing Preferences: Your consent to receive promotional emails, SMS messages, or push notifications.

2.2 Information Collected Automatically

• Device Information: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, bet amounts, win/loss records, session duration, clickstream data, and referral sources.
• Location Data: Approximate geographic location derived from your IP address to ensure compliance with jurisdictional restrictions.
• Cookies and Tracking Technologies: Data collected through cookies, web beacons, and similar technologies (see Section 5 for details).

2.3 Information from Third Parties

• Payment Processors: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment providers.
• Identity Verification Services: Verification results from third-party KYC service providers used to confirm your identity and age.
• Fraud Prevention Services: Risk assessment data from anti-fraud and anti-money laundering screening services.

03 How We Use Your Data

jl36 processes your personal information only for lawful purposes and on the basis of one or more of the following legal grounds: your consent, the performance of a contract with you, compliance with a legal obligation, or our legitimate interests as a gaming operator.

jl36 will not use your personal information for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

04 Data Sharing & Disclosure

jl36 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your personal information with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, solely to facilitate deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to verify your identity and comply with regulatory requirements.
• Fraud Prevention & AML Services: Anti-fraud and anti-money laundering screening providers used to detect and prevent financial crime.
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on our behalf under strict data processing agreements.
• Customer Support Tools: Third-party customer relationship management (CRM) and live chat platforms used to manage support interactions.
• Regulatory Authorities: Philippine government agencies and regulatory bodies, including but not limited to the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and applicable gaming regulators, where disclosure is required by law.
• Law Enforcement: Law enforcement agencies or courts of competent jurisdiction where disclosure is required by a valid legal order, warrant, or subpoena.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of jl36's assets, your personal information may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

05 Cookies & Tracking Technologies

jl36 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver relevant content. The following types of cookies are used:

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the jl36 Platform. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is set. Refer to your browser's help documentation for instructions.

jl36 may also use web beacons (also known as pixel tags or clear GIFs) in emails and on the Platform to track whether emails have been opened and to monitor user interactions with Platform content.

06 Data Security

jl36 implements a comprehensive set of technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and the jl36 Platform is encrypted using 256-bit SSL/TLS protocols. Sensitive data stored in our systems is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data is restricted to authorized jl36 personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular security training.
• Firewalls & Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and continuous security monitoring.
• Regular Security Audits: jl36 conducts regular penetration testing and security audits to identify and remediate vulnerabilities in our systems.
• Two-Factor Authentication: jl36 offers two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Data Breach Response: In the event of a personal data breach that poses a risk to your rights and freedoms, jl36 will notify the National Privacy Commission and affected users within 72 hours of becoming aware of the breach, as required by Philippine law.

07 Data Retention

jl36 retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a period of seven (7) years following account closure, in compliance with Philippine anti-money laundering regulations and tax laws.
• Transaction Records: Retained for a minimum of seven (7) years from the date of the transaction, as required by applicable financial regulations.
• KYC / Identity Verification Documents: Retained for seven (7) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Communications: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.
• Cookies and Analytics Data: Retained for periods ranging from session-only (for essential cookies) to up to two (2) years (for analytics cookies), depending on the cookie type.

When personal information is no longer required, jl36 will securely delete or anonymize it in accordance with our data disposal procedures.

08 Your Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal information held by jl36:

• Right to Be Informed: You have the right to be informed about how your personal information is collected, used, and disclosed. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal information jl36 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal information we hold about you. You can update most account information directly through your jl36 account settings.
• Right to Erasure: You have the right to request deletion of your personal information where it is no longer necessary for the purposes for which it was collected, subject to any overriding legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to jl36's overriding legitimate grounds.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that jl36 has violated your data privacy rights.

09 Children's Privacy

The jl36 Platform is strictly intended for adults aged 21 years and above. jl36 does not knowingly collect, use, or disclose personal information from individuals under the age of 21.

If jl36 becomes aware that it has inadvertently collected personal information from a person under the age of 21, we will take immediate steps to delete that information from our systems and close the associated account. Any funds deposited by an underage user will be handled in accordance with applicable law and our Terms & Conditions.

If you are a parent or guardian and believe that your child has registered on the jl36 Platform, please contact us immediately at [email protected] so that we can take appropriate action.

10 International Data Transfers

jl36 primarily processes and stores personal information within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers, KYC verification services, and fraud prevention platforms — may process data in other countries.

Where personal information is transferred outside the Philippines, jl36 ensures that appropriate safeguards are in place to protect your data, including:

• Entering into data processing agreements with third-party processors that incorporate standard contractual clauses approved by the National Privacy Commission;
• Transferring data only to countries or organizations that provide an adequate level of data protection as determined by the National Privacy Commission; or
• Obtaining your explicit consent to the transfer where required by law.

By using the jl36 Platform, you acknowledge and consent to the transfer of your personal information to countries outside the Philippines where our service providers operate, subject to the safeguards described above.

11 Changes to This Privacy Policy

jl36 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or business operations. When we make material changes to this Policy, we will notify registered users via email or a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how jl36 is protecting your personal information.

Your continued use of the jl36 Platform after any changes to this Privacy Policy become effective constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must stop using the Platform and may request account closure in accordance with our Terms & Conditions.

12 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way jl36 handles your personal information, please contact our Data Protection Officer:

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the chat widget on the jl36 Platform
• Response Time: We aim to respond to all privacy-related inquiries within 15 business days

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.