jl37 Privacy Policy

1. Introduction

jl37.asia ("jl37", "we", "us", "the Platform") is a PAGCOR-licensed online gaming platform operated for Filipino players. This Privacy Policy ("Policy") governs the collection, use, storage, disclosure, and protection of personal data provided to or collected by jl37 in the course of operating the platform and providing gaming services to registered users ("Players", "you").

By registering a jl37 account or using any part of the platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree, you must not register or continue using jl37.

This Policy should be read alongside jl37's Terms & Conditions, which together constitute the full agreement between jl37 and its registered players.

2. Personal Data We Collect

jl37 collects personal data through several channels: account registration, platform use, payment processing, KYC verification, and customer support interactions. The categories of data collected include:

• Identity Data: Legal full name, date of birth, nationality, and government-issued Philippine identification document number (e.g., PhilSys, UMID, passport, driver's licence, voter's ID);
• Contact Data: Email address, mobile phone number, and residential address within the Philippines;
• Financial Data: GCash account reference, BPI/BDO/Metrobank account identifiers, Maya wallet reference, and transaction records. Full bank account or card numbers are not stored by jl37 — these are handled exclusively by the respective payment processors;
• Gaming Activity Data: Bet history, game session logs, win/loss records, bonus usage, and session timestamps;
• Technical Data: IP address, device type, operating system, browser type, and mobile network identifier (Smart, Globe, DITO);
• Behavioural Data: Clickstream data, pages visited, game preferences, and time spent on the platform;
• Communications Data: Records of live chat conversations, email correspondence, and support ticket content;
• KYC & Compliance Data: Copies of identification documents uploaded during verification, selfie photographs where required, and source-of-funds declarations where requested under AML procedures.

3. How We Use Your Personal Data

jl37 processes your personal data for the following purposes:

• Account Management: To create, maintain, verify, and secure your jl37 player account;
• Service Delivery: To provide access to all gaming products, process deposits and withdrawals, and calculate winnings in PHP;
• Identity Verification (KYC): To verify that you are who you say you are, that you are at least 21 years of age, and that you are not on any applicable exclusion list;
• Regulatory Compliance: To fulfil jl37's obligations under PAGCOR licensing conditions, Republic Act 9160 (AMLA), and RA 10173 (Data Privacy Act);
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, account abuse, multi-accounting, and money laundering;
• Customer Support: To respond to your queries, resolve complaints, and improve service quality;
• Responsible Gaming: To monitor gaming patterns, enforce self-imposed limits, and comply with PAGCOR responsible gaming directives;
• Platform Improvement: To analyse usage patterns, identify bugs, and improve the jl37 user experience;
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates — subject to your communication preferences and applicable opt-out rights.

4. Legal Basis for Processing

jl37 processes your personal data under the following legal bases as recognised under RA 10173:

• Consent: Where you have explicitly consented to data processing, such as marketing communications;
• Contractual Necessity: Processing required to deliver the services you registered for, including account creation, payment processing, and gaming access;
• Legal Obligation: Processing required by PAGCOR regulations, AMLA obligations, tax reporting requirements, or other applicable Philippine law;
• Legitimate Interests: Processing undertaken for fraud prevention, platform security, and service improvement where these interests are not overridden by your data subject rights.

5. Data Sharing & Disclosure

jl37 does not sell your personal data to third parties. Your data may be shared in the following limited circumstances:

• Payment Processors: GCash (GXI), Maya (Voyager), BPI, BDO, Metrobank, Coins.ph, and other payment partners receive transaction data necessary to process deposits and withdrawals. Each processor operates under its own privacy policy and data protection obligations;
• KYC & Identity Verification Providers: Third-party services used to verify Philippine government-issued identification documents and perform liveness checks;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies — where disclosure is required by law, court order, or regulatory direction;
• Group Companies: Affiliated entities within jl37's corporate group for internal compliance, reporting, and operational purposes, subject to equivalent data protection obligations;
• Professional Advisers: Legal counsel, auditors, and accountants engaged by jl37 under confidentiality obligations;
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all jl37 assets, player data may be transferred to the acquiring entity, with notice provided to affected players.

6. Cookies & Tracking Technologies

jl37 uses cookies and similar tracking technologies to operate the platform, maintain session state, and analyse usage patterns. Categories of cookies used include:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication tokens and security cookies. They cannot be disabled without preventing platform access;
• Functional Cookies: Remember your preferences such as language, stake defaults, and game display settings;
• Analytical Cookies: Collect aggregate, anonymised data about how players navigate jl37 to help us improve the platform. No personally identifiable data is shared with external analytics providers;
• Security Cookies: Used to detect and mitigate fraudulent logins, bot activity, and abuse of the jl37 platform.

You may manage cookie preferences through your browser settings. Note that disabling cookies may affect platform functionality. jl37 does not deploy third-party advertising or cross-site tracking cookies.

7. Data Retention

jl37 retains personal data for the periods necessary to fulfil the purposes described in this Policy, subject to the following minimum retention obligations:

• Active Account Data: Retained for the duration of your account relationship with jl37 plus an additional period as required by law;
• Transaction & Betting Records: Retained for a minimum of five (5) years following the transaction date, in compliance with AMLA record-keeping requirements;
• KYC Documents: Retained for a minimum of five (5) years from the date of account closure or the end of the business relationship;
• Support Communications: Retained for a period of two (2) years from the date of the last communication;
• Marketing Data: Retained until you withdraw consent or request deletion, whichever occurs first.

After the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents identification of the data subject.

8. Data Security

jl37 implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data processed. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the jl37 platform;
• Hashed storage of passwords using industry-standard one-way cryptographic functions — jl37 cannot read your raw password;
• Access controls and role-based permissions limiting employee access to personal data to those with a legitimate operational need;
• Regular security assessments and penetration testing of the jl37 platform infrastructure;
• Player-facing security features including optional two-factor authentication and active session management.

In the event of a personal data breach that poses a risk to your rights and freedoms, jl37 will notify the National Privacy Commission (NPC) within 72 hours of discovery and will notify affected players as required by the NPC's breach notification guidelines.

9. Your Data Subject Rights

Under RA 10173 and its Implementing Rules, you have the following rights with respect to your personal data held by jl37:

• Right to Access: Request a copy of the personal data jl37 holds about you;
• Right to Rectification: Request correction of inaccurate or incomplete personal data;
• Right to Erasure: Request deletion of your personal data where retention is no longer necessary — subject to jl37's legal retention obligations;
• Right to Object: Object to processing based on legitimate interests, including direct marketing;
• Right to Data Portability: Receive your personal data in a structured, machine-readable format where technically feasible;
• Right to Withdraw Consent: Withdraw previously given consent for specific processing activities. Withdrawal does not affect processing that occurred prior to withdrawal;
• Right to Lodge a Complaint: File a complaint with the National Privacy Commission (NPC) if you believe jl37 has breached your data privacy rights.

To exercise any of these rights, contact jl37's Data Protection Officer at [email protected] with the subject line "Data Privacy Request". jl37 will respond within the timeframes required by the NPC.

10. Children & Minors

jl37 is strictly a platform for adults. We do not knowingly collect personal data from any person under 21 years of age. Registration requires submission of a valid Philippine government-issued ID, and KYC verification is designed to confirm that all players meet the minimum age requirement.

If jl37 discovers that personal data has been collected from a person under 21 years of age, that account will be immediately suspended, all balances forfeited, and the personal data deleted in accordance with applicable data protection law. If you believe a minor has registered on jl37, please notify us at [email protected].

11. Third-Party Services

The jl37 platform integrates third-party services including game content providers, payment gateways (GCash, Maya, BPI, BDO, Metrobank, Coins.ph), and KYC verification tools. When you use these integrated services, your data may be processed by the relevant third party under their own privacy policies. jl37 does not control third-party data practices and recommends reviewing the privacy policies of any third-party service you interact with through the platform.

jl37 selects third-party partners who demonstrate compliance with RA 10173 and, where applicable, equivalent international data protection standards. Data processing agreements are in place with all third parties who process personal data on behalf of jl37.

12. Changes to This Privacy Policy

jl37 reserves the right to update this Privacy Policy at any time to reflect changes in legal requirements, platform operations, or data processing practices. Material changes will be communicated to registered players via email or in-platform notification at least 7 days before the effective date.

The current version of this Policy is always available at jl37.asia/privacy-policy, with the effective date displayed at the top. Continued use of jl37 after the effective date of any amendment constitutes your acceptance of the updated Policy.

13. Contact & Data Protection Officer

For data privacy inquiries, data subject rights requests, or complaints, contact jl37's designated Data Protection Officer:

• Email: [email protected] — subject line: "Data Privacy Request"
• Live Chat: Available on jl37.asia from 8:00 AM to 12:00 MN PHT

For complaints that cannot be resolved directly with jl37, you may lodge a formal complaint with the National Privacy Commission of the Philippines through their official channels.