Privacy Policy

01 Introduction

jl36 ("jl36," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our platform at https://jl36.app. This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information when you access or use the jl36 website, mobile platform, games, and related services (collectively, the "Platform").

This Policy is intended to be read alongside our Terms & Conditions and Responsible Gaming Policy, which together form the complete agreement governing your use of the jl36 Platform.

By registering for a jl36 account or continuing to use the 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. If you do not agree with this Policy, please discontinue use of the Platform.

02 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, jl36 is the personal information controller responsible for your personal data collected through the Platform.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer (DPO) at [email protected]. We aim to respond to all data privacy inquiries within five (5) business days.

03 Personal Data We Collect

jl36 collects personal data through several channels. The categories of data we collect, and the circumstances in which we collect them, are set out below.

3.1 Data You Provide Directly

• Registration data: Full name, date of birth, email address, mobile number, and residential address (required to create a jl36 account).
• Identity verification data: Government-issued ID (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence), selfie or liveness check images, and proof of address documents — collected as part of our Know Your Customer (KYC) process.
• Payment data: GCash mobile number, PayMaya account details, bank account details (account name, account number, bank name), and debit card details (card number, expiry date — stored in tokenized form only). Full card numbers are never stored on jl36 servers.
• Communications data: Messages, queries, and feedback you submit via live chat, email, or any other communication channel with jl36 support.

3.2 Data We Collect Automatically

• Device and technical data: IP address, browser type and version, operating system, device identifiers, screen resolution, and time zone settings.
• Usage data: Pages visited, games played, session duration, click patterns, deposit and withdrawal history, bonus usage, and wagering activity on the jl36 Platform.
• Location data: General geographic location derived from your IP address, used to verify eligibility and comply with jurisdictional restrictions.
• Cookie and tracking data: Information collected via cookies, web beacons, and similar technologies as described in Section 8 of this Policy.

3.3 Data From Third Parties

• Identity verification providers: Results of KYC and anti-money laundering (AML) checks conducted by our third-party verification partners.
• Payment processors: Transaction confirmation data from GCash, PayMaya, and banking partners to reconcile deposits and withdrawals.
• Fraud prevention services: Risk scores and flagging data from fraud detection providers used to protect the integrity of the jl36 Platform.

04 How We Use Your Personal Data

jl36 uses the personal data we collect for the following purposes:

• Account creation and management: To register your jl36 account, verify your identity, and maintain your account in good standing.
• Service delivery: To provide access to games, process deposits and withdrawals, apply bonuses, and deliver the full jl36 gaming experience.
• Identity verification and KYC compliance: To verify that you meet the minimum age requirement of 21 years and to comply with anti-money laundering (AML) obligations under Philippine law.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming patterns, identify potentially problematic behaviour, and apply responsible gaming tools such as deposit limits and self-exclusion where appropriate.
• Customer support: To respond to your queries, resolve disputes, and improve the quality of our support services.
• Legal and regulatory compliance: To comply with applicable Philippine laws, gaming regulations, tax obligations, and lawful requests from regulatory authorities including PAGCOR and the National Privacy Commission.
• Platform improvement: To analyse usage patterns, conduct research, and improve the features, performance, and content of the jl36 Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and news about jl36 — but only where you have consented to receive such communications. You may opt out at any time.

jl36 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

05 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, jl36 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — including account registration, game access, and payment processing — is necessary to deliver the jl36 service you have signed up for.
• Legal obligation: Certain processing activities — including KYC verification, AML checks, and record-keeping — are required by Philippine law and gaming regulations. We cannot waive these obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement is carried out on the basis of jl36's legitimate interests, provided those interests are not overridden by your rights and freedoms.
• Consent: Where we rely on your consent — such as for marketing communications or optional cookies — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

06 Data Sharing and Disclosure

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

• Identity verification and KYC providers: Third-party services that assist us in verifying your identity and age, and in conducting AML screening.
• Payment processors: GCash, PayMaya, and banking partners who process your deposits and withdrawals. These parties process your financial data under their own privacy policies and applicable Philippine financial regulations.
• Fraud prevention and security providers: Services that help us detect and prevent fraudulent activity, account takeovers, and other security threats.
• IT infrastructure and hosting providers: Cloud and server infrastructure providers who host the jl36 Platform and store data on our behalf, under strict data processing agreements.
• Customer support platforms: Tools used to manage and respond to player support queries, including live chat and ticketing systems.
• Regulatory and law enforcement authorities: Where required by Philippine law, court order, or lawful request from PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other competent authorities.
• Professional advisers: Lawyers, auditors, and accountants who provide professional services to jl36, subject to confidentiality obligations.

07 Data Retention

jl36 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account and identity data: Retained for the duration of your jl36 account and for a minimum of five (5) years following account closure, in compliance with Philippine AML and gaming record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and related regulations.
• Customer support communications: Retained for three (3) years from the date of the last interaction, to support dispute resolution and service improvement.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, to demonstrate compliance.
• Technical and usage data: Typically retained for thirteen (13) months from collection, after which it is aggregated or deleted.

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

08 Cookies and Tracking Technologies

The jl36 Platform uses cookies and similar tracking technologies (including web beacons and local storage) to enhance your experience, remember your preferences, and analyse how the Platform is used. The types of cookies we use are as follows:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in to your jl36 account and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and game history to personalise your jl36 experience.
• Analytics cookies: Collect anonymised data about how players use the Platform — such as which games are most popular and where players encounter difficulties — to help us improve jl36.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of jl36 marketing campaigns. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the jl36 Platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the service.

09 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and jl36 servers.
• Encryption at rest for sensitive personal and financial data stored on jl36 infrastructure.
• Payment card tokenisation — full card numbers are never stored on jl36 servers; only secure tokens provided by our payment processor are retained.
• Multi-factor authentication (MFA) options for player accounts to prevent unauthorised access.
• Role-based access controls ensuring that jl36 staff can only access personal data necessary for their specific job function.
• Regular security audits and penetration testing conducted by independent security professionals.
• Intrusion detection and monitoring systems operating 24/7 to identify and respond to potential security incidents.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jl36 will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and its implementing rules.

While jl36 takes all reasonable steps to protect your data, no internet transmission or electronic storage system is completely secure. You are responsible for keeping your jl36 login credentials confidential and for notifying us immediately if you suspect any unauthorised access to your account.

10 Your 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 jl36:

• Right to be informed: The right to know that your personal data is being collected and processed, and to receive clear information about how it is used — as provided in this Privacy Policy.
• Right of access: The right to request a copy of the personal data jl36 holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to 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.
• Right to object: 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: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days. We may need to verify your identity before processing your request.

11 Children's Privacy and Age Restriction

The jl36 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

During registration, all players are required to confirm that they are at least 21 years of age. jl36 conducts age verification checks as part of its KYC process and will suspend any account where the player is found to be under 21, with all associated balances forfeited.

If you believe that a minor has registered on the jl36 Platform or that we have inadvertently collected personal data from a person under 21, please contact us immediately at [email protected]. We will investigate and take appropriate action, including deletion of the minor's data, without undue delay.

12 Third-Party Links

The jl36 Platform may contain references to third-party services such as payment providers. Please note that once you leave the jl36 Platform, this Privacy Policy no longer applies. Third-party services operate under their own privacy policies, and jl36 is not responsible for the data practices of any third party.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of jl36, particularly your chosen payment provider (e.g., GCash or PayMaya).

13 Changes to This Privacy Policy

jl36 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or the features of the Platform. When we make material changes, we will notify you by posting a prominent notice on the jl36 Platform and, where appropriate, by sending a notification to your registered email address.

The "Last Updated" date at the top of this Policy indicates when the most recent changes were made. We encourage you to review this Policy periodically to stay informed about how jl36 protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

14 Contact Us

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

• Email: [email protected]
• Live Chat: Available 24/7 directly on the jl36 Platform

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been respected. The NPC can be reached through their official government channels.

For responsible gaming concerns, self-exclusion requests, or problem gambling support, please visit our Responsible Gaming page.