Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 36jll ("Company," "we," "us," or "our"), operating the online gaming platform at https://36jll.cam (the "Platform"), collects, uses, stores, processes, discloses, and protects personal information obtained from users ("User," "Player," "you," or "your") in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and other applicable Philippine data protection regulations. This Policy applies to all personal information collected through the 36jll Platform, whether through account registration, gaming activities, customer support interactions, promotional communications, or any other means of engagement with our services.

At 36jll, we recognize that privacy is fundamental to building trust with our Filipino players. We are committed to transparency regarding our data practices and to implementing robust security measures to safeguard your personal information from unauthorized access, disclosure, alteration, or destruction. By accessing or using the 36jll Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with any aspect of this Policy, you must immediately discontinue use of the Platform and refrain from creating or maintaining an account.

2. Information We Collect

2.1 Information You Provide Directly

When you register for an account with 36jll, you provide personal information including but not limited to your full legal name as it appears on government-issued identification, date of birth, residential address (including street, barangay, city/municipality, and province), mobile phone number, email address, and preferred username. During account verification processes, you may provide copies of government-issued identification documents such as Philippine passport, driver's license, voter's ID, or UMID card, as well as proof of address documents including utility bills, bank statements, or government correspondence.

When conducting financial transactions on the 36jll Platform, you provide payment information including GCash mobile numbers, PayMaya account details, bank account numbers, and other financial identifiers necessary to process deposits and withdrawals. You may also provide additional information when communicating with customer support, participating in promotions or surveys, or voluntarily submitting feedback about your gaming experience.

2.2 Information Collected Automatically

The 36jll Platform automatically collects certain technical information when you access or use our services. This includes your Internet Protocol (IP) address, device identifiers (such as mobile device IMEI or advertising IDs), browser type and version, operating system, screen resolution, language preferences, referring URLs, pages visited, time spent on pages, and clickstream data showing your navigation path through the Platform. We collect session information including login times, logout times, and duration of gaming sessions.

We collect detailed gaming activity data including games played, bets placed, outcomes, winnings and losses, bonus utilization, wagering patterns, and progression through bonus requirements. This gaming data helps 36jll detect fraudulent activities, ensure compliance with bonus terms, identify problem gambling patterns, and improve our service offerings based on actual player behavior and preferences.

2.3 Information from Third Parties

36jll may receive information about you from third-party sources including payment processors who verify and process your deposits and withdrawals, identity verification services that confirm the authenticity of your documentation, fraud prevention services that screen for suspicious activities, and marketing partners who may refer you to our Platform. We may also collect publicly available information from Philippine government databases or social media platforms if you choose to connect your social media accounts to your 36jll account.

3. How We Use Your Information

36jll uses collected personal information for the following legitimate business purposes:

• Account Management: To create, maintain, and administer your player account, verify your identity and age, process account updates, and provide customer support services.
• Transaction Processing: To process deposits, withdrawals, and other financial transactions, prevent fraudulent payments, and maintain accurate financial records for accounting and regulatory compliance.
• Gaming Services: To provide access to games, track gaming activity, determine winnings and losses, apply bonus terms, enforce betting limits, and ensure fair gameplay across the Platform.
• Security and Fraud Prevention: To detect and prevent fraudulent activities, multiple account creation, bonus abuse, money laundering, collusion between players, and other violations of our Terms and Conditions.
• Regulatory Compliance: To comply with Philippine gaming regulations enforced by PAGCOR, anti-money laundering laws, tax reporting requirements, and other legal obligations applicable to 36jll as a licensed online gaming operator.
• Marketing and Communications: To send promotional offers, bonus notifications, loyalty rewards updates, platform news, and other marketing communications where you have provided consent or where permitted by law.
• Responsible Gaming: To monitor gaming patterns that may indicate problem gambling, enforce responsible gaming limits you set, facilitate self-exclusion requests, and provide access to responsible gaming resources.
• Platform Improvement: To analyze user behavior, identify technical issues, improve game offerings, enhance user interface design, and develop new features based on Filipino player preferences.
• Legal Proceedings: To establish, exercise, or defend legal claims, respond to lawful requests from Philippine government authorities, and comply with court orders or legal processes.

4. Legal Basis for Processing

Under Philippine data protection law, 36jll processes your personal information based on the following legal grounds:

• Consent: You have provided explicit consent for specific processing activities, particularly for marketing communications and optional data collection beyond what is necessary for platform operation.
• Contractual Necessity: Processing is necessary to perform our contractual obligations under the Terms and Conditions governing your use of the 36jll Platform, including account creation, transaction processing, and service provision.
• Legal Obligation: Processing is required to comply with Philippine laws and regulations including PAGCOR gaming regulations, anti-money laundering laws, tax reporting requirements, and data retention mandates.
• Legitimate Interests: Processing serves legitimate business interests of 36jll such as fraud prevention, platform security, service improvement, and customer support, provided such interests do not override your fundamental privacy rights.

5. Information Sharing and Disclosure

5.1 Third-Party Service Providers

36jll shares personal information with carefully selected third-party service providers who assist in operating the Platform and providing services to Filipino players. These service providers include payment processors (such as GCash and PayMaya) who facilitate deposits and withdrawals, identity verification services that confirm player identities, game providers who supply casino games and slots, customer support platforms, email service providers, data analytics services, and cybersecurity vendors. All service providers are contractually obligated to maintain confidentiality and use your information solely for the purposes of providing services to 36jll.

5.2 Legal and Regulatory Disclosures

We may disclose personal information when required by Philippine law, court order, or regulatory directive. This includes disclosures to PAGCOR for licensing compliance, to the Anti-Money Laundering Council (AMLC) for suspicious transaction reporting, to the Bureau of Internal Revenue (BIR) for tax purposes, and to law enforcement agencies investigating criminal activities. 36jll will make such disclosures only to the extent legally required and will take reasonable steps to notify affected users where permissible under law.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy involving 36jll, personal information may be transferred to successor entities or acquiring parties. In such circumstances, we will require the receiving party to continue protecting your information in accordance with this Privacy Policy and applicable Philippine law.

5.4 Information We Do Not Sell

36jll does not sell, rent, or trade your personal information to third parties for their marketing purposes. Your data is never provided to data brokers, marketing companies, or other organizations seeking to monetize personal information outside the context of providing services directly to you through our Platform.

6. Data Security

36jll implements industry-standard technical and organizational security measures to protect personal information from unauthorized access, disclosure, alteration, or destruction. Security measures include 256-bit SSL encryption for data transmission between your device and our servers, encrypted storage of sensitive information in secure databases, regular security audits and penetration testing, firewalls and intrusion detection systems, access controls limiting employee access to personal data based on job responsibilities, and incident response procedures for data breaches.

Despite these security measures, no internet transmission or electronic storage system is completely secure. While 36jll strives to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

7. Data Retention

36jll retains personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce agreements. Account information and transaction records are retained for a minimum of five (5) years following account closure as required by Philippine anti-money laundering regulations and PAGCOR record-keeping requirements. Gaming activity logs are retained for at least one (1) year for operational purposes and fraud detection.

After the required retention period expires, 36jll will securely delete or anonymize personal information unless continued retention is necessary for legitimate legal, regulatory, or business purposes. You may request information about our retention practices and applicable retention periods by contacting our Data Protection Officer.

8. Your Privacy Rights

Under the Philippine Data Privacy Act, you have the following rights regarding your personal information held by 36jll:

• Right to Access: You may request copies of personal information we hold about you, including account details, transaction history, and gaming records.
• Right to Rectification: You may request correction of inaccurate or incomplete personal information through your account settings or by contacting customer support.
• Right to Erasure: You may request deletion of your personal information, subject to legal retention requirements and legitimate business needs such as fraud prevention.
• Right to Object: You may object to processing of your personal information for direct marketing purposes or other processing based on legitimate interests.
• Right to Data Portability: You may request a copy of your personal information in a structured, commonly used format for transfer to another service provider.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time, though withdrawal does not affect the lawfulness of processing before withdrawal.
• Right to Lodge Complaints: You may file complaints with the National Privacy Commission of the Philippines if you believe 36jll has violated your privacy rights.

To exercise these rights, please contact our Data Protection Officer using the contact information provided in Section 12 of this Policy. We will respond to requests within thirty (30) days unless an extension is necessary due to request complexity, in which case we will notify you of the delay.

9. Cookies and Tracking Technologies

The 36jll Platform uses cookies, web beacons, and similar tracking technologies to enhance user experience, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device that help us recognize you on return visits, remember your preferences, and track your navigation through the Platform. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain until deleted or expire).

Types of cookies used by 36jll include essential cookies necessary for platform functionality, performance cookies that collect anonymous usage statistics, functionality cookies that remember your preferences, and marketing cookies that track your interaction with promotional content. You can control cookie settings through your browser preferences, though disabling certain cookies may limit your ability to use platform features.

10. Children's Privacy

The 36jll Platform is intended exclusively for individuals who are at least twenty-one (21) years of age. We do not knowingly collect personal information from minors. If we discover that we have inadvertently collected information from a person under 21 years of age, we will promptly delete such information from our systems. Parents or guardians who believe their child has provided personal information to 36jll should contact us immediately so we can take appropriate action.

11. International Data Transfers

While 36jll primarily operates within the Philippines and serves Filipino players, some service providers may be located outside the Philippines, potentially resulting in international data transfers. When transferring personal information internationally, 36jll ensures adequate safeguards are in place, including contractual data protection clauses and verification that receiving countries provide adequate data protection standards comparable to Philippine law.

12. Changes to This Privacy Policy

36jll reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated through email notification to your registered email address and through prominent notice on the Platform. Your continued use of the Platform following notice of changes constitutes acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to remain informed about how we protect your information.

13. Contact Information

For questions, concerns, or complaints regarding this Privacy Policy or our data practices, or to exercise your privacy rights, please contact our Data Protection Officer:

Data Protection Officer
36jll Online Gaming Platform
Email: [email protected]
Customer Support: Available 24/7 via live chat

For complaints regarding privacy violations that remain unresolved through our internal processes, you may contact the National Privacy Commission of the Philippines:

National Privacy Commission
5th Floor, Philippine International Convention Center
Vicente Sotto Street, Pasay City, Metro Manila

Data Category	Purpose	Retention Period
Account Information	Identity verification, account management	5 years after account closure
Transaction Records	Payment processing, financial reporting	5 years (regulatory requirement)
Gaming Activity	Service provision, fraud detection	1 year minimum
Marketing Preferences	Communication management	Until consent withdrawn
Support Communications	Customer service, dispute resolution	3 years