jl37 Privacy Policy

1.1 This Privacy Policy ("Policy") is issued by jl37 ("jl37," "we," "us," or "our") and applies to all personal data collected through the jl37 website at jl37.org and any related services, features, or communications (collectively, the "Platform").

1.2 jl37 is committed to protecting the privacy and security of all players, particularly those based in the Philippines. This Policy is designed to comply with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

1.3 By registering an account on the jl37 Platform or by continuing to use the 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, you must not use the Platform.

1.4 This Policy should be read alongside the jl37 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated herein by reference.

2.1 jl37 collects personal data in the following categories:

2.2 jl37 does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive personal information is collected, it is handled with the heightened protections required by the DPA.

2.3 You are not required to provide all requested data, but failure to provide certain information (particularly KYC documentation) may result in restrictions on your account, including the suspension of withdrawal privileges.

3.1 jl37 uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your jl37 account, including processing deposits and withdrawals.
• Identity Verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR requirements and Philippine AML regulations.
• Service Delivery: To provide access to jl37's games, promotions, and platform features.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Regulatory Compliance: To comply with our obligations under Philippine law, including reporting requirements under the Anti-Money Laundering Act (AMLA) and PAGCOR licensing conditions.
• Responsible Gaming: To monitor player behaviour for signs of problem gambling and to administer self-exclusion, deposit limits, and other responsible gaming tools.
• Customer Support: To respond to your enquiries, complaints, and support requests.
• Marketing Communications: To send you promotional offers, bonuses, and platform updates where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: To analyse usage patterns and improve the jl37 Platform's performance, features, and user experience.
• Legal Claims: To establish, exercise, or defend legal claims arising in connection with your use of the Platform.

4.1 Under the Philippine Data Privacy Act, jl37 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and jl37 (i.e., the Terms & Conditions), including account management, payment processing, and service delivery.
• Legal Obligation: Processing is necessary to comply with jl37's legal obligations under Philippine law, including PAGCOR licensing requirements, the AMLA, and NPC regulations.
• Legitimate Interests: Processing is necessary for jl37's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and certain non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5.1 jl37 does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

5.2 jl37 may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulatory obligation.
• Payment Service Providers: GCash, PayMaya/Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services engaged to assist with KYC compliance.
• IT & Platform Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on jl37's behalf under strict data processing agreements.
• Legal & Professional Advisers: Lawyers, auditors, and compliance consultants, subject to professional confidentiality obligations.
• Law Enforcement: Where jl37 is required or permitted by law to disclose data to law enforcement or other government agencies.

5.3 All third-party service providers engaged by jl37 are contractually required to process personal data only in accordance with jl37's instructions and applicable Philippine data protection law.

6.1 jl37 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit jl37.org.

6.2 jl37 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled without affecting core functionality (e.g., session management, login authentication).
• Performance & Analytics Cookies: Used to understand how players interact with the Platform, identify errors, and improve performance. Data collected is aggregated and anonymised where possible.
• Functional Cookies: Used to remember your preferences (e.g., language settings, display preferences) to personalise your experience.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

6.3 You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jl37 Platform.

7.1 jl37 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law.

7.2 As a general guide:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Marketing Data: Retained until you withdraw consent or opt out of marketing communications.
• Support Communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for legal proceedings.

7.3 Upon expiry of the applicable retention period, jl37 will securely delete or anonymise your personal data.

8.1 jl37 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and jl37.org;
• 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 and vulnerability assessments;
• Multi-factor authentication for administrative access to jl37 systems;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl37 will notify the National Privacy Commission and affected players in accordance with the requirements of the DPA and NPC Circular No. 16-03.

8.3 While jl37 takes all reasonable steps to protect your data, no internet transmission is completely secure. You are responsible for maintaining the confidentiality of your jl37 account credentials.

9.1 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 jl37:

• Right to Be Informed: You have the right to be informed of how your personal data is collected, used, and processed, as set out in this Policy.
• Right to Access: You have the right to request a copy of the personal data jl37 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 data jl37 holds about you.
• Right to Erasure or Blocking: You have the right to request the deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, or where processing is unlawful, subject to jl37's legal retention obligations.
• Right to Object: You have 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: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe jl37 has processed your personal data in violation of the DPA.

9.2 To exercise any of the above rights, please contact jl37's Data Protection Officer using the contact details in Section 13 of this Policy. jl37 will respond to all verified requests within fifteen (15) business days, in accordance with NPC guidelines.

9.3 jl37 may need to verify your identity before processing any data subject request to ensure that personal data is not disclosed to unauthorised persons.

10.1 The jl37 Platform is strictly intended for persons aged twenty-one (21) years and above. jl37 does not knowingly collect personal data from individuals under the age of 21.

10.2 If jl37 becomes aware that personal data has been collected from a person under 21 years of age, it will immediately delete such data and close the associated account. If you believe that a minor has registered on the jl37 Platform, please contact us immediately using the details in Section 13.

11.1 jl37 primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data outside the Philippines — for example, to cloud infrastructure providers or KYC verification partners — jl37 ensures that appropriate safeguards are in place to protect your data in accordance with the DPA and NPC requirements.

11.2 Such safeguards may include contractual clauses approved by the NPC, adequacy decisions, or other legally recognised transfer mechanisms. jl37 will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without your explicit consent or a valid legal basis.

12.1 jl37 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The revised Policy will be published on this page with an updated "Last Updated" date.

12.2 Where changes are material, jl37 will endeavour to notify registered players via email or an in-platform notification prior to the changes taking effect. Your continued use of the jl37 Platform following the publication of any amendment constitutes your acceptance of the revised Policy.

12.3 We encourage you to review this Policy periodically to stay informed about how jl37 protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or jl37's handling of your personal data, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.