Privacy Policy
3jl3 Casino — Philippines

This Privacy Policy ("Policy") is issued by 3jl3 Casino ("3jl3", "we", "us", "our") and applies to all personal data collected, processed, and stored in connection with your use of the 3jl3 online gaming platform accessible at 3jl3.win, including all associated mobile-optimised interfaces, account management systems, customer support channels, and promotional communications.

This Policy is intended to comply with the requirements of the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and the applicable guidelines issued by the National Privacy Commission (NPC). It also reflects the data handling obligations applicable to PAGCOR-regulated online gaming operators.

This Policy does not apply to the websites, applications, or services of third-party game providers, payment processors, or other partners whose services are accessible through or in connection with 3jl3. Those parties maintain their own privacy policies, which you are encouraged to review independently.

For the purposes of the Data Privacy Act of 2012, 3jl3 Casino acts as the Personal Information Controller (PIC) with respect to all personal data collected through the 3jl3 platform. 3jl3 is responsible for determining the purposes and means of processing your personal data.

Where 3jl3 engages third-party service providers (e.g., payment processors, KYC verification services, cloud infrastructure providers) to process personal data on its behalf, those parties act as Personal Information Processors (PIPs) and are bound by data processing agreements that prohibit any use of personal data outside the scope of the services they provide to 3jl3.

3jl3 collects and processes the following categories of personal data about you:

3jl3 does not collect sensitive personal information (as defined in RA 10173) beyond what is strictly required for identity verification and regulatory compliance. Where sensitive data (e.g., government ID details) is collected, it is treated with the heightened protections specified under the Data Privacy Act.

3jl3 collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or updating your account profile;
• Automated collection: Technical and usage data collected automatically when you access and use the 3jl3 platform, including through cookies, server logs, and device fingerprinting technologies;
• Third-party sources: Identity verification data received from our KYC verification service providers; payment confirmation data received from payment processors (GCash, Maya, BPI, BDO, etc.); fraud screening data from anti-fraud service providers;
• Publicly available sources: Where permitted by applicable law, information from publicly accessible sources used for AML and fraud prevention purposes.

Under the Data Privacy Act of 2012, 3jl3 processes your personal data on the following legal bases:

3jl3 uses your personal data for the following purposes:

• Account creation and management: To register your account, verify your identity, and maintain your account in good standing;
• Age and eligibility verification: To confirm that you are at least 21 years of age and otherwise eligible to use the 3jl3 platform under PAGCOR regulations;
• Service delivery: To provide access to games, process deposits and withdrawals, and manage your account wallet;
• Customer support: To respond to enquiries, resolve complaints, and investigate disputes;
• Regulatory compliance: To fulfil our PAGCOR licensing obligations, AML reporting requirements under AMLA, and other applicable legal obligations;
• Fraud and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the platform;
• Responsible gaming: To monitor gaming activity for patterns associated with problem gambling and to provide proactive responsible gaming interventions in compliance with PAGCOR requirements;
• Platform improvement: To analyse usage patterns, optimise platform performance, and improve the overall player experience;
• Marketing (consent-based): To send you promotional offers, bonus notifications, and personalised recommendations where you have consented to receive such communications.

3jl3 does not sell your personal data. We share your personal data only in the following limited circumstances, and only to the extent strictly necessary:

• Service providers and processors: Third-party companies that provide services to 3jl3, including payment processing (GCash, Maya, BPI network, etc.), KYC verification services, cloud infrastructure providers, customer support platform providers, and fraud screening services. All such parties are bound by data processing agreements;
• Regulatory authorities: PAGCOR and other Philippine government bodies (including the AMLC and NPC) where disclosure is required by law, regulation, court order, or other legal process;
• Group companies: Affiliated entities within the 3jl3 corporate group, where necessary for service delivery, compliance, or centralised data management — all subject to the same data protection standards as set out in this Policy;
• Professional advisers: Lawyers, auditors, and consultants retained by 3jl3 in connection with the operation of its business, subject to strict professional confidentiality obligations;
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of 3jl3's assets, your personal data may be transferred to the acquiring party, subject to this Policy or an equivalent privacy policy.

All third parties with whom 3jl3 shares personal data are required to maintain appropriate technical and organisational security measures and to process personal data only for the specified, authorised purposes.

The 3jl3 platform uses cookies and similar tracking technologies (including local storage, session storage, and device fingerprinting) to deliver and improve the platform experience. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function, including session authentication, security token management, and fraud prevention. These cookies cannot be disabled without impairing core platform functionality;
• Functional cookies: Enable enhanced functionality and personalisation, such as remembering your language preference, game layout settings, and responsible gaming limit configurations;
• Analytics cookies: Used to understand how players interact with the 3jl3 platform, identify performance issues, and improve the overall experience. Data collected is aggregated and anonymised where possible;
• Marketing cookies: Used to deliver relevant promotional content within the 3jl3 platform based on your gaming history and preferences, where you have consented to marketing communications.

3jl3 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulatory obligations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 3jl3's data disposal procedures. Anonymised data (from which you can no longer be identified) may be retained indefinitely for aggregated analytics purposes.

3jl3 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the 3jl3 platform;
• Encryption at rest for sensitive personal and financial data stored on 3jl3 systems;
• Access controls limiting access to personal data to authorised personnel who require it for legitimate business purposes, on a strict need-to-know basis;
• Multi-factor authentication for administrative access to systems containing personal data;
• Regular security assessments including vulnerability scanning, penetration testing, and third-party security audits;
• Incident response procedures designed to detect, contain, and remediate security incidents promptly, with NPC notification in accordance with RA 10173 where a personal data breach occurs;
• Staff training on data privacy obligations under RA 10173 for all personnel with access to personal data.

In the event of a personal data breach that is likely to result in harm to you, 3jl3 will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, in accordance with the requirements of RA 10173.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 3jl3. These rights may be exercised by contacting our Data Privacy Officer at [email protected]:

• Right to be Informed: The right to know whether 3jl3 processes your personal data, what data is held, and the purposes and bases for processing — as set out in this Privacy Policy;
• Right of Access: The right to obtain a copy of the personal data we hold about you, subject to applicable exceptions;
• Right to Correction: The right to correct inaccurate or incomplete personal data about you. You may update most profile information directly through your 3jl3 account dashboard;
• Right to Erasure ("Right to be Forgotten"): 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 3jl3's legal retention obligations under AMLA and PAGCOR requirements;
• Right to Object: The right to object to the processing of your personal data for direct marketing or, in certain circumstances, for other purposes based on legitimate interests;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format, and to request its transmission to another data controller, where technically feasible;
• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe that 3jl3 has not handled your personal data in compliance with RA 10173.

3jl3 will respond to verifiable privacy rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with notice provided to you of the extension and its reasons.

Age verification is conducted as part of the mandatory KYC process for all 3jl3 accounts. If 3jl3 becomes aware that personal data has been collected from a person under the age of 21, that data will be deleted without delay and the associated account will be permanently closed.

Parents and guardians who believe that a minor may have accessed or registered on the 3jl3 platform are encouraged to contact us immediately at [email protected] so that the matter can be investigated and resolved promptly.

The 3jl3 platform is operated primarily for Filipino players and within the Philippine regulatory framework. In the ordinary course of operating a global technology platform, certain personal data may be transferred to, stored, or processed in countries outside the Philippines — for example, where cloud infrastructure providers or game software vendors maintain data processing facilities.

Where personal data is transferred outside the Philippines, 3jl3 ensures that appropriate safeguards are in place to protect the data in accordance with the requirements of RA 10173, including:

• Binding contractual clauses that require the recipient to protect your personal data to standards equivalent to Philippine law;
• Transfers only to recipients in countries that the NPC has determined to provide an adequate level of protection; or
• Other safeguards approved by the NPC for cross-border transfers.

You may request information about the specific safeguards in place for any cross-border transfer of your personal data by contacting our Data Privacy Officer.

3jl3 may revise this Privacy Policy from time to time to reflect changes in applicable Philippine law, NPC guidelines, PAGCOR regulatory requirements, our data processing practices, or the services we offer. The effective date of the current version is clearly stated at the top of this document.

Where a revision materially affects your rights or the way in which we process your personal data, 3jl3 will provide advance notice via email to your registered address or via a prominent notice on the 3jl3 platform at least fourteen (14) days before the updated Policy takes effect.

Your continued use of the 3jl3 platform after the effective date of a revised Privacy Policy constitutes your acknowledgement of the revised Policy. If you do not agree to the revised Policy, please cease use of the platform and contact us to close your account.

For all privacy-related enquiries, requests to exercise your data subject rights, complaints, or questions about this Policy, please contact the 3jl3 Data Privacy Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC is the competent supervisory authority for the Data Privacy Act of 2012.