Privacy Policy – 3jl9 Casino

1. Who We Are

This Privacy Policy applies to 3jl9 ("3jl9," "we," "us," or "our"), the operator of the online gaming platform accessible at https://3jl9.org ("Platform"). 3jl9 acts as the personal information controller (PIC) in respect of the personal data collected through the Platform, as defined under Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations.

This Policy applies to all users of the 3jl9 Platform, including registered players, visitors who browse the Platform without registering, and individuals who contact our customer support team. By using the 3jl9 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2. Personal Data We Collect

3jl9 collects the following categories of personal data, depending on how you interact with the Platform:

2.1 Registration and Identity Data

• Full legal name
• Date of birth (for age verification — you must be 21 or older)
• Philippine mobile number
• Email address
• Username and encrypted password
• Residential address (province, city/municipality)

2.2 Identity Verification (KYC) Data

• Government-issued photo ID (e.g., Philippine passport, driver's license, PhilSys National ID, SSS ID, UMID, PRC ID)
• Proof of address documents
• Selfie or liveness verification image (where required)

2.3 Financial and Transaction Data

• GCash or PayMaya account number (masked)
• Bank account details for bank transfer transactions (masked)
• Deposit and withdrawal history
• Transaction amounts in Philippine Peso (PHP)

2.4 Gaming Activity Data

• Game session logs (game title, duration, wager amounts, outcomes)
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion status)

2.5 Technical and Device Data

• IP address and approximate geolocation (country/region level)
• Device type, operating system, and browser version
• Session timestamps and login history
• Cookie identifiers and analytics data (see Section 7)

2.6 Communications Data

• Customer support chat transcripts and email correspondence
• Survey responses and feedback submissions

Data Category	Examples	Required?
Identity	Name, date of birth, email, mobile	Mandatory for registration
KYC Documents	Government ID, proof of address	Mandatory before first withdrawal
Financial	GCash number, bank details, transaction history	Mandatory for deposits/withdrawals
Gaming Activity	Game logs, wager history, bonus usage	Automatically collected during play
Technical	IP address, device info, cookies	Automatically collected on access
Communications	Support chat logs, feedback	Collected when you contact us

3. How We Collect Your Data

3jl9 collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey.
• Automatically: When you access or use the Platform, our servers and analytics tools automatically collect technical and device data, including IP address, session data, and cookie identifiers.
• From payment processors: When you initiate a deposit or withdrawal, our payment partners (GCash, PayMaya, and partner banks) share transaction confirmation data with 3jl9 for reconciliation purposes.
• From identity verification providers: When you complete KYC, our verification partner processes your ID documents and returns a verification result to 3jl9. The raw document images are handled in accordance with the verification provider's own privacy policy.
• From game providers: Our third-party game studios provide aggregated game session data to 3jl9 for account crediting, dispute resolution, and responsible gaming monitoring purposes.

4. How We Use Your Personal Data

3jl9 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 3jl9 Platform.
• Service delivery: To process deposits and withdrawals, credit game winnings, apply bonuses, and provide access to all Platform features.
• Regulatory compliance: To fulfill our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012, including KYC verification, transaction monitoring, and suspicious activity reporting.
• Responsible gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and apply deposit or session limits set by the player.
• Customer support: To respond to your inquiries, resolve disputes, and improve our support services.
• Security and fraud prevention: To detect, investigate, and prevent unauthorized access, fraudulent transactions, bonus abuse, and other prohibited conduct.
• Platform improvement: To analyze usage patterns, identify technical issues, and develop new features based on player behavior and feedback.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — only where you have consented or where we have a legitimate interest, and always with an opt-out option.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 3jl9 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you agreed to upon registration (e.g., account management, payment processing, game delivery).
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AMLA obligations, and NPC data privacy requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where our legitimate interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and optional analytics, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

3jl9 does not sell your personal data. We share personal data only in the following limited circumstances:

6.1 Service Providers

We share data with trusted third-party service providers who assist in operating the 3jl9 Platform, including payment processors (GCash, PayMaya, partner banks), identity verification providers, game studios, cloud hosting providers, and customer support platforms. All service providers are contractually bound to process data only on our instructions and in compliance with applicable privacy laws.

6.2 Regulatory and Law Enforcement Authorities

3jl9 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government authorities where required by law, court order, or regulatory directive.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 3jl9'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.

6.4 With Your Consent

We may share your data with third parties in other circumstances where you have provided explicit prior consent.

7. Cookies and Tracking Technologies

3jl9 uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Essential cookies: Required for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without breaking core Platform functionality.
• Analytics cookies: Used to collect aggregated, anonymized data about how players navigate the Platform, which pages are most visited, and where technical errors occur. This data helps us improve the user experience.
• Preference cookies: Store your language, display, and notification preferences so you don't have to re-enter them on each visit.
• Marketing cookies: Used to deliver relevant promotional content within the 3jl9 Platform. These are only activated where you have consented.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will affect your ability to log in and use the Platform. For analytics and marketing cookies, you may opt out via your 3jl9 account settings.

8. Data Retention

3jl9 retains your personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following minimum retention periods:

• 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 PAGCOR and AMLA record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• KYC documents: Retained for a minimum of five (5) years after account closure or the completion of the relevant transaction, whichever is later.
• Customer support records: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year for audit purposes.

After the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

9. Data Security

3jl9 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data in transit is protected by TLS 1.2 or higher (256-bit SSL). Sensitive data at rest (including passwords and financial identifiers) is encrypted using industry-standard algorithms.
• Access controls: Access to personal data is restricted to authorized 3jl9 personnel on a strict need-to-know basis. All staff with data access undergo privacy and security training.
• Two-factor authentication (2FA): Available on all player accounts and mandatory for internal administrative access.
• Penetration testing: The 3jl9 Platform undergoes regular third-party security audits and penetration testing to identify and remediate vulnerabilities.
• Incident response: 3jl9 maintains a documented data breach response plan. In the event of a personal data breach that poses a real risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) within 72 hours and affected players without undue delay, as required by the DPA.
• Secure data disposal: Physical and digital records containing personal data are disposed of securely using certified destruction methods at the end of their retention period.

10. Your Data Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 3jl9:

• Right to be informed: You have the right to know what personal data 3jl9 collects about you, how it is used, and with whom it is shared — which is the purpose of this Privacy Policy.
• Right of access: You may request a copy of the personal data 3jl9 holds about you, including information on how it has been processed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data in your 3jl9 account.
• Right to erasure: You may 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 under PAGCOR and AMLA regulations.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format for transfer to another service provider.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to 3jl9's overriding legal obligations.
• Right to lodge a complaint: If you believe 3jl9 has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer (DPO) using the details provided in Section 13. We will respond to all verified data subject requests within fifteen (15) business days, as required by the DPA.

11. Children's Privacy and Age Restriction

The 3jl9 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations enforced by PAGCOR. 3jl9 does not knowingly collect personal data from individuals under the age of 21.

During registration, all users are required to confirm that they are at least 21 years of age. Prior to processing any withdrawal, 3jl9 verifies the player's age through our KYC identity verification process. Any account found to belong to a person under 21 years of age will be immediately suspended, all balances will be returned to the verified payment source, and the personal data of the underage individual will be securely deleted.

If you are a parent or guardian and believe that a minor has registered on the 3jl9 Platform, please contact our support team immediately at the details provided in Section 13.

12. Updates to This Privacy Policy

3jl9 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. When we make material changes to this Policy, we will notify registered players via email or in-platform notification at least seven (7) days before the changes take effect.

The updated Policy will always be published on this page with the effective date clearly noted at the top. Your continued use of the 3jl9 Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must stop using the Platform and may request account closure by contacting our support team.

13. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 3jl9, please contact our Data Protection Officer (DPO):

• Data Protection Officer: 3jl9 Privacy Office
• Email: [email protected]
• Support Email: [email protected]
• Live Chat: Available 24/7 via the 3jl9 Platform
• Response Time: Within 15 business days for data subject requests

For complaints that have not been resolved to your satisfaction by 3jl9, you may contact the National Privacy Commission of the Philippines through their official channels.