36jl93 Privacy Policy

1. About This Policy

This Privacy Policy is issued by 36jl93 ("the Platform," "we," "us," "our") and applies to all personal information collected through the 36jl93 website, mobile platform, customer support channels, and any other service operated under the 36jl93 brand.

This Policy is drafted in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines ("DPA"), its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission ("NPC"). It should be read together with the 36jl93 Terms & Conditions, which govern your overall use of the platform.

By accessing or using the 36jl93 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 any part of this Policy, you should discontinue use of the platform and contact our support team to close your account.

2. Data We Collect

36jl93 collects personal data that is adequate, relevant, and limited to what is necessary for the purposes outlined in this Policy. The categories of personal data we collect include:

2.1 Identity & Contact Data

• Full legal name as it appears on a government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Gender (optional, for account personalisation)
• Residential address, including city and province (e.g., Metro Manila, Cebu, Davao, Quezon City, Makati)
• Email address and mobile number
• Government-issued ID number and ID document images submitted for KYC verification

2.2 Financial Data

• GCash mobile number or PayMaya account reference
• BPI, BDO, or Metrobank account name (not full account number) for bank transfer verification
• Transaction history: deposit amounts, withdrawal requests, wager amounts, and balances denominated in Philippine Peso (₱)
• Payment method ownership verification documents submitted during KYC

2.3 Technical & Usage Data

• IP address and approximate geolocation at the time of login and wagering activity
• Device type, operating system, browser type and version
• Session logs, including login timestamps, session duration, pages visited, and features used
• Betting and gaming activity records: games played, bets placed, results, and bonus usage
• Customer support interaction logs, including live chat transcripts

2.4 Preference & Behavioural Data

• Language and display preferences saved in your account settings
• Marketing communication preferences (opted-in email and SMS subscriptions)
• Responsible gaming settings: deposit limits, session timers, and self-exclusion elections
• Inferred interests based on gaming activity, used for personalised game recommendations

3. How We Collect Your Data

36jl93 collects personal data through the following channels:

• Direct submission: Information you provide when creating an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated collection: Technical and usage data collected automatically when you interact with the platform, including through cookies, server logs, and session tracking tools.
• Third-party verification services: Identity and document verification data returned by our KYC and anti-money laundering (AML) service providers following the verification of documents you submit.
• Payment processors: Confirmation data returned by GCash, PayMaya, BPI, BDO, and Metrobank following deposit or withdrawal transactions, sufficient to reconcile your account balance.
• Fraud prevention systems: Device fingerprint data and behavioural signals collected by our fraud detection systems to identify and prevent account abuse, bonus fraud, and unauthorised access.

4. Why We Use Your Data

36jl93 processes your personal data for the following purposes:

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 36jl93 processes your personal data on one or more of the following legal bases depending on the specific processing activity:

• Contractual necessity: Processing required to perform our obligations under the 36jl93 Terms & Conditions, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine law, including KYC and AML obligations under PAGCOR regulations and RA 9160.
• Legitimate interests: Processing carried out for 36jl93's legitimate business interests — such as fraud prevention, platform security, and service improvement — where those interests are not overridden by your data protection rights.
• Consent: Processing for purposes where consent is required, including marketing communications and certain cookies. You may withdraw consent at any time without affecting processing carried out before withdrawal.

6. Data Sharing & Third Parties

36jl93 does not sell your personal data. We share personal data with third parties only in the following circumstances, and only to the extent strictly necessary for the stated purpose:

6.1 Service Providers

We engage carefully selected third-party service providers who process personal data on our behalf under binding data processing agreements. These include: KYC and identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), game content providers, fraud detection services, cloud hosting infrastructure, and customer support software vendors. All such providers are contractually prohibited from using your data for their own purposes.

6.2 Regulatory and Law Enforcement Authorities

36jl93 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, or courts of competent jurisdiction in the Philippines where we are legally required or compelled to do so, or where we reasonably believe disclosure is necessary to prevent fraud, money laundering, or other criminal activity.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of the 36jl93 business, personal data held by 36jl93 may be transferred to the acquiring entity. You will be notified of any such transfer and any material change to data processing practices that results from it, in advance of the transfer taking effect.

7. Data Retention

36jl93 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following retention guidelines:

• Active accounts: Personal data is retained for the lifetime of your account plus five (5) years following account closure, in line with PAGCOR record-keeping requirements and Philippine AML obligations.
• Transaction records: Financial transaction records are retained for a minimum of five (5) years following the date of each transaction, as required by the Anti-Money Laundering Act.
• KYC documents: Identity verification documents are retained for five (5) years following account closure or the date of last transaction, whichever is later.
• Customer support records: Support interaction logs are retained for two (2) years following the resolution of the relevant support case.
• Marketing data: Contact details held for marketing purposes are deleted within thirty (30) days of receiving a valid opt-out or erasure request.
• Anonymised analytics data: Aggregated, anonymised usage data from which you cannot be identified may be retained indefinitely for platform improvement purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. You may request early deletion of your data subject to our legal retention obligations — see Section 8 for details.

8. Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 36jl93. To exercise any of these rights, contact our Data Protection Officer at the details provided in Section 13.

9. Cookies & Tracking Technologies

The 36jl93 platform uses cookies and similar tracking technologies to operate core platform functions, improve user experience, and — where you have consented — deliver relevant promotional content. The categories of cookies we use are:

• Strictly necessary cookies: Essential for platform operation, including session authentication, load balancing, and security. These cannot be disabled without disrupting your use of the platform.
• Functional cookies: Remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Analytics cookies: Collect aggregated, pseudonymised data about how players use the platform — pages visited, features used, error logs — to help us identify and fix issues and improve overall performance.
• Marketing cookies: Used only where you have explicitly consented, to serve relevant promotional offers on the 36jl93 platform. We do not use third-party advertising networks to serve ads on external sites.

You can manage your cookie preferences at any time through your browser settings or the cookie preference panel within your 36jl93 account. Disabling non-essential cookies will not prevent you from using the platform's core gaming features.

10. Children & Minors

The 36jl93 platform is strictly intended for adults aged 21 years and over, in accordance with Philippine law. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under the age of 21 without verifiable parental or guardian consent, we will immediately close the associated account, delete the personal data in question, and return any deposited funds to the original payment source.

11. Security Measures

36jl93 implements technical, organisational, and administrative security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Our security infrastructure includes:

• Encryption in transit: All data transmitted between your device and the 36jl93 platform is encrypted using TLS 1.3 with 256-bit AES encryption.
• Encryption at rest: Sensitive personal data fields stored in our databases are encrypted at rest using industry-standard symmetric encryption.
• Password hashing: Account passwords are hashed using a strong one-way cryptographic algorithm. 36jl93 staff cannot view or retrieve your plain-text password.
• Access controls: Access to personal data within 36jl93's internal systems is restricted on a strict need-to-know basis, with role-based access controls and audit logging for all privileged access.
• Fraud detection: Automated systems monitor account activity in real time for signs of unauthorised access, suspicious transactions, and account takeover attempts.
• Incident response: In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 36jl93 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will inform affected players without undue delay.

While we take every reasonable measure to protect your data, no internet-based platform can guarantee absolute security. You play an important role by keeping your 36jl93 login credentials confidential and notifying us immediately of any suspected unauthorised account activity.

12. Policy Updates

36jl93 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory guidance. The "Last Updated" date at the top of this page will always reflect the date of the most recent revision.

Where updates are material — meaning they significantly affect how we process your personal data or your rights under this Policy — we will provide at least fourteen (14) calendar days' advance notice via a prominent notice on the platform or by email to the address associated with your 36jl93 account. Your continued use of the platform following the effective date of any update constitutes your acknowledgement of the revised Policy.

For minor or clarificatory updates that do not materially affect your rights, changes may take effect immediately upon publication. We encourage you to review this Policy periodically.

13. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 36jl93, you may contact our Data Protection Officer (DPO) directly. All data rights requests and privacy complaints will be acknowledged within five (5) business days and resolved within thirty (30) calendar days.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines (NPC). Please note that the NPC generally expects complainants to have first attempted to resolve the matter directly with the data controller before filing a formal complaint.