Privacy Policy — 36jlapp Philippines

1. About This Policy

This Privacy Policy ("Policy") is issued by 36jlapp ("Company," "we," "us," or "our") and applies to all personal data processed in connection with your use of the 36jlapp online gaming platform, including the website at 36jlapp.app, any associated mobile applications, and all related services (collectively, the "Platform").

36jlapp is committed to protecting the privacy and security of your personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. We are also guided by PAGCOR's data governance requirements applicable to licensed online gaming operators.

By registering an account or using the 36jlapp Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform and contact us to close your account.

2. Personal Data We Collect

36jlapp collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include:

2.1 Identity & Contact Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth (for age verification — you must be 21 or older)
• Gender
• Nationality and country of residence
• Registered email address
• Mobile phone number (used for OTP verification and account security)
• Residential address (barangay, city/municipality, province, ZIP code)

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (Philippine passport, driver's license, SSS ID, UMID, PhilSys National ID, or Voter's ID)
• Proof of address documents (utility bills, bank statements, or barangay certificates)
• Selfie photographs submitted for liveness verification

2.3 Financial Data

• GCash or PayMaya account details (mobile number and registered name)
• Bank account details (bank name, account name, account number) for bank transfer transactions
• Debit card details (card number, expiry date — CVV is never stored)
• Transaction history (deposits, withdrawals, and wager records)

2.4 Gaming & Behavioral Data

• Game session logs (games played, wagers placed, outcomes, session duration)
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, self-exclusion status)
• Customer support interaction records

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Unique device identifiers
• Login timestamps and session activity logs
• Cookie and tracking technology data (see Section 7)

3. How We Collect Your Data

36jlapp collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and behavioral data collected automatically when you access and use the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance databases; payment confirmation data from GCash, PayMaya, and banking partners.
• Regulatory sources: Self-exclusion and problem gambling data shared by PAGCOR or other recognized gambling regulatory authorities.

4. How We Use Your Personal Data

36jlapp uses your personal data for the following purposes:

• Account creation and management: To register your account, verify your identity, and maintain your player profile on the 36jlapp Platform.
• Age verification: To confirm that you are at least 21 years of age, as required by Philippine gambling law. This is a non-negotiable legal obligation.
• KYC and AML compliance: To fulfill our obligations under the Anti-Money Laundering Act (RA 9160, as amended) and PAGCOR's KYC requirements, including screening against sanctions lists and politically exposed persons (PEP) databases.
• Transaction processing: To process deposits, withdrawals, and bonus credits accurately and securely.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible gaming: To monitor gaming behavior for signs of problem gambling, enforce deposit limits and self-exclusion requests, and comply with PAGCOR's responsible gaming requirements.
• Security and fraud prevention: To detect, investigate, and prevent unauthorized access, fraud, cheating, and other prohibited conduct on the Platform.
• Platform improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the 36jlapp Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your explicit consent and only through channels you have opted into. You may withdraw consent at any time.
• Legal compliance: To comply with applicable Philippine laws, PAGCOR regulations, court orders, and lawful requests from government authorities.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you — including account management, transaction processing, and customer support.
• Legal obligation: Processing required to comply with Philippine law, including AML obligations, PAGCOR regulatory requirements, and age verification mandates.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our legitimate interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and optional data uses, where you have given explicit, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

36jlapp does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following circumstances and only to the extent necessary:

6.1 Service Providers

We engage trusted third-party service providers who process data on our behalf under strict data processing agreements, including:

• KYC and identity verification providers
• Payment processors (GCash, PayMaya, banking partners)
• Cloud hosting and infrastructure providers
• Customer support platform providers
• Fraud detection and AML screening services

6.2 Regulatory and Law Enforcement Authorities

36jlapp is required by law to share certain data with:

• PAGCOR — as our gaming regulator, including player data, transaction records, and responsible gaming reports.
• Anti-Money Laundering Council (AMLC) — covered transaction reports and suspicious transaction reports as required by RA 9160.
• National Privacy Commission (NPC) — in the event of a personal data breach or upon lawful request.
• Philippine law enforcement agencies — in response to valid court orders, subpoenas, or lawful government requests.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 36jlapp's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer.

7. Cookies & Tracking Technologies

36jlapp 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 visit a website. We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences (such as language settings and responsible gaming tool configurations) to improve your experience.
• Analytics cookies: Help us understand how players use the Platform so we can improve performance and usability. Data collected is aggregated and anonymized where possible.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized login attempts.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to the 36jlapp Platform. 36jlapp does not use third-party advertising or behavioral tracking cookies.

8. Data Retention

36jlapp retains your personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following minimum retention periods required by Philippine law:

• Account and KYC records: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Marketing consent records: Retained for as long as you remain a registered player, plus three (3) years after account closure.
• Technical and device logs: Retained for twelve (12) months from the date of collection, unless required for an ongoing investigation.

When personal data is no longer required, 36jlapp will securely delete or anonymize it in accordance with NPC-approved data disposal procedures.

9. Data Security

36jlapp implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 36jlapp Platform.
• Encryption at rest for sensitive data stored in our databases, including KYC documents and financial records.
• Two-factor authentication (2FA) via SMS OTP for all player accounts.
• Role-based access controls ensuring that only authorized 36jlapp personnel can access personal data, and only to the extent required for their job function.
• Regular security audits and penetration testing conducted by independent third-party security firms.
• Intrusion detection systems and 24/7 security monitoring of the Platform infrastructure.
• Data breach response procedures in compliance with NPC Circular 16-03, including notification to affected data subjects and the NPC within 72 hours of discovering a breach that poses a real risk of serious harm.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 36jlapp:

• Right to be informed: The right to know what personal data we collect, how we use it, and with whom we share it — which is the purpose of this Policy.
• Right of access: The right to request a copy of the personal data we hold about you, including your account information, KYC records, and transaction history.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You can update most account information directly from your Account Settings page.
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations (see Section 8). Note that we cannot delete data we are legally required to retain.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time via your Account Settings or by contacting support.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated. The NPC can be reached at privacy.gov.ph (do not click — type directly into your browser).

To exercise any of these rights, please contact our Data Protection Officer (DPO) using the details in Section 15. We will respond to all verified requests within fifteen (15) business days, as required by the Data Privacy Act.

11. Children & Minors

The 36jlapp Platform is strictly intended for persons aged 21 years and above. We do not knowingly collect personal data from individuals under 21. If we discover that personal data has been collected from a person under 21, we will immediately suspend the associated account, delete the data, and report the matter to PAGCOR as required by regulation.

12. Cross-Border Data Transfers

Some of 36jlapp's service providers — including cloud infrastructure and KYC verification partners — may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to the Philippines, 36jlapp ensures that appropriate safeguards are in place, including:

• Standard contractual clauses approved by the NPC or equivalent data protection authority.
• Binding corporate rules where the recipient is part of the same corporate group.
• Your explicit consent, where required by the Data Privacy Act.

All cross-border data transfers are conducted in compliance with NPC regulations and are documented in our data processing register.

13. Third-Party Links

The 36jlapp Platform may contain references to third-party services (such as payment providers). This Policy applies only to data processed by 36jlapp. We are not responsible for the privacy practices of third-party services, and we encourage you to review their privacy policies before providing any personal data to them.

14. Changes to This Privacy Policy

36jlapp reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, we will notify registered players via email to their registered address and/or via a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of the 36jlapp Platform after the effective date of any revision constitutes your acceptance of the updated Policy.

15. Contact Us & Data Protection Officer

36jlapp has appointed a Data Protection Officer (DPO) in compliance with the Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact:

• Data Protection Officer, 36jlapp
• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 on the 36jlapp Platform

We aim to respond to all data privacy requests within fifteen (15) business days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.