368jl Privacy Policy – How We Handle Your Personal Data

1. Introduction and Scope

This Privacy Policy applies to all personal data collected, processed, and stored by 368jl in connection with the operation of its online gaming platform accessible at 368jl.vip. It covers data collected from players located in the Philippines and governs our data handling practices in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR).

By registering an account, depositing funds, or using any service on the 368jl platform, you acknowledge that you have read 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 Privacy Policy, you must not use the 368jl platform.

This Privacy Policy is to be read in conjunction with the 368jl Terms & Conditions and our Responsible Gaming Policy.

2. Data Controller Information

For the purposes of the Data Privacy Act of 2012 and applicable PAGCOR regulations, the data controller responsible for your personal data processed through the 368jl platform is:

• Platform Name: 368jl
• Website: 368jl.vip
• Regulatory Authority: Philippine Amusement and Gaming Corporation (PAGCOR)
• Data Protection Officer Contact: [email protected]

Players may direct all data privacy inquiries, access requests, and complaints to the Data Protection Officer at the contact details above.

3. Personal Data We Collect

368jl collects the following categories of personal data from players:

3.1 Registration and Identity Data

• Full legal name as it appears on a valid Philippine government-issued ID
• Date of birth (used to verify the PAGCOR-mandated 21-year minimum age)
• Philippine mobile number (Globe, Smart, DITO, or TNT)
• Email address
• Username and encrypted account password

3.2 Identity Verification (KYC) Data

• Scanned or photographed copies of government-issued Philippine ID (Passport, UMID, PhilSys ID, Driver's Licence, Voter's ID, or PhilHealth card)
• Proof of address documents (e.g., utility bill, bank statement) where required
• Selfie photographs for identity confirmation where required by our fraud prevention processes

3.3 Financial and Transaction Data

• GCash account name and registered mobile number
• Maya account name and registered mobile number
• Bank account name, bank name, and account number (for bank transfer transactions)
• Transaction history including deposit amounts, withdrawal amounts, dates, and reference numbers

3.4 Gaming Activity Data

• Game session history, bet amounts, win/loss records, and game preferences
• Sports betting selections and wager history
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion status)

3.5 Technical and Device Data

• IP address and geolocation data at login and during active sessions
• Device type, operating system, browser type and version
• Session duration and platform interaction logs
• Cookie identifiers and similar tracking data (see Section 11)

3.6 Communications Data

• Records of customer support interactions via live chat, email, or SMS
• Complaint and dispute records
• Marketing preference settings and communication opt-in/opt-out records

4. How We Collect Your Data

368jl collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or respond to a promotion.
• Automatically — through cookies, server logs, and analytics tools that record your interactions with the 368jl platform during active sessions.
• From payment processors — GCash, Maya, and partner banking institutions provide transaction confirmation data to 368jl to reconcile deposits and withdrawals.
• From identity verification partners — where 368jl engages third-party KYC service providers to verify government ID documents, those providers may process your identity data on our behalf.
• From fraud prevention services — third-party fraud detection tools may cross-reference your registration data against known fraud databases. This is done to protect all 368jl players from fraudulent activity on the platform.

5. Legal Basis for Processing

368jl processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity — processing required to fulfil the player agreement, including account management, game delivery, payment processing, and customer support.
• Legal obligation — processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) obligations, and NPC data management requirements.
• Legitimate interests — processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests do not override your fundamental privacy rights.
• Consent — processing for direct marketing communications, where you have provided express opt-in consent, and for non-essential cookies where your consent is obtained through our cookie consent mechanism.

6. How We Use Your Personal Data

368jl uses the personal data we collect for the following purposes:

• Creating and managing your 368jl player account
• Verifying your identity and age in compliance with PAGCOR regulations and AMLA obligations
• Processing deposits and withdrawals via GCash, Maya, and Philippine bank transfer
• Delivering and personalising your gaming experience across all 368jl products
• Detecting, investigating, and preventing fraudulent activity, collusion, and other prohibited conduct
• Monitoring compliance with 368jl's responsible gaming policies and applying player-protection measures where appropriate
• Sending transactional communications including account notifications, deposit confirmations, withdrawal updates, and security alerts
• Sending promotional communications where you have opted in to receive them
• Responding to customer support inquiries, complaints, and dispute escalations
• Complying with reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities
• Improving platform performance, user experience, and game content through aggregated analytics

7. Disclosure to Third Parties

368jl does not sell your personal data to third parties. We may share your data with the following categories of recipients under strict contractual confidentiality obligations:

• Payment processors — GCash (GXI), Maya (Voyager Innovations), and Philippine banking partners to process your financial transactions.
• Game content providers — JILI, PG Soft, Pragmatic Play, Evolution Gaming, and other licensed game developers who operate the game engines available on 368jl, to the extent required for game delivery and audit purposes.
• KYC and fraud prevention services — identity verification and fraud detection providers engaged to verify player identity and protect the integrity of the platform.
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement authorities where required by law or court order.
• Professional advisors — legal, audit, and compliance advisors who are bound by professional confidentiality obligations.
• IT and hosting providers — infrastructure and cloud services partners who host and maintain the 368jl platform under data processing agreements that impose equivalent privacy protections.

Any third-party data processor engaged by 368jl is required to process personal data only on documented instructions from 368jl and to implement appropriate technical and organisational security measures.

8. International Data Transfers

Some of 368jl's third-party service providers, including game content providers and infrastructure partners, may process data outside of the Philippines. Where such transfers occur, 368jl ensures that appropriate safeguards are in place in accordance with the DPA's cross-border transfer provisions, including contractual clauses that require recipient parties to observe data protection standards equivalent to those applicable under Philippine law.

9. Data Retention

368jl retains personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, and in any event for the minimum periods required under applicable Philippine law:

• Account and KYC data — retained for a minimum of 5 years following account closure, in compliance with PAGCOR licensing conditions and AMLA record-keeping obligations.
• Financial transaction records — retained for a minimum of 5 years following the date of each transaction, as required by the Anti-Money Laundering Act.
• Gaming activity logs — retained for 3 years following the relevant activity date, or longer where a dispute or regulatory investigation is ongoing.
• Customer support records — retained for 3 years following resolution of the relevant support interaction or complaint.
• Marketing consent records — retained until you withdraw consent or for 3 years following your last interaction with 368jl, whichever is earlier.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with 368jl's data disposal procedures.

10. Security Measures

368jl implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit Secure Sockets Layer (SSL) encryption for all data transmitted between your device and 368jl's servers
• Encryption of sensitive data fields (including passwords and financial account numbers) at rest using industry-standard encryption protocols
• Two-factor authentication (2FA) available for all player accounts
• IP activity monitoring and automated alerts for anomalous login patterns
• Role-based access controls restricting 368jl staff access to personal data on a need-to-know basis
• Regular security testing and vulnerability assessments of the 368jl platform infrastructure
• Staff training on data protection obligations and information security protocols

Notwithstanding these measures, no internet-based platform can guarantee absolute security. In the event of a personal data breach affecting your rights and freedoms, 368jl will notify the National Privacy Commission and affected players in accordance with NPC Circular 16-03 (Personal Data Breach Management).

11. Cookies and Tracking Technologies

368jl uses cookies and similar tracking technologies on its platform to ensure platform functionality, enhance user experience, and support analytics and fraud prevention operations. The categories of cookies used are:

• Strictly necessary cookies — essential for platform operation, including session management, authentication, and security. These cannot be disabled without impairing core platform functionality.
• Functional cookies — remember your preferences such as language settings and last-visited game categories to improve your experience on return visits.
• Analytics cookies — used to collect aggregated, anonymised data about how players interact with the 368jl platform, enabling us to identify and fix usability issues and improve content.
• Fraud prevention cookies — used by third-party fraud detection tools to identify suspicious device patterns or access behaviours.

You may manage non-essential cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the 368jl platform.

12. Your Rights Under Philippine Data Privacy Law

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by 368jl:

• Right to be Informed — to be notified of how your data is collected, processed, and stored before or at the time of collection.
• Right to Access — to request a copy of the personal data we hold about you and information about how it is being processed.
• Right to Rectification — to request correction of any inaccurate, incomplete, or outdated personal data in your 368jl account.
• Right to Erasure or Blocking — to request deletion or suspension of processing of your personal data where the data is no longer necessary for the purpose it was collected, or where you withdraw consent (subject to legal retention obligations).
• Right to Object — to object to the processing of your personal data for direct marketing purposes at any time. We will cease such processing upon receipt of your objection.
• Right to Data Portability — to receive a structured, machine-readable copy of your personal data that you have provided to 368jl.
• Right to Lodge a Complaint — to file a complaint with the National Privacy Commission (NPC) if you believe 368jl has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact the 368jl Data Protection Officer at [email protected]. We will respond to all verified requests within 15 business days in accordance with NPC guidelines.

13. Children and Minors

The 368jl platform is strictly prohibited to individuals under 21 years of age, in accordance with PAGCOR regulations. 368jl does not knowingly collect personal data from individuals under 21. If we become aware that personal data has been collected from a player who is under the minimum age, we will immediately close the relevant account and delete all associated personal data in accordance with applicable legal requirements.

If you are a parent or guardian and believe that your child or ward has registered an account on the 368jl platform, please contact our support team immediately at [email protected].

14. Changes to This Privacy Policy

368jl may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or platform functionality. Where changes are material, we will notify registered players via email or a prominent notice on the 368jl platform at least 7 days before the changes take effect. The "Last Updated" date at the top of this page will be revised each time this Privacy Policy is modified. Continued use of the 368jl platform following the effective date of any revision constitutes acceptance of the updated Privacy Policy.

15. Contact and Complaints

For all privacy-related enquiries, data subject requests, or complaints regarding 368jl's data handling practices, please contact:

• Data Protection Officer – 368jl: [email protected]
• Live Chat: Available 24/7 through the 368jl platform

If you are not satisfied with 368jl's response to your privacy complaint, you have the right to escalate your complaint directly to the National Privacy Commission of the Philippines (NPC) through the NPC's official complaint mechanism.