Privacy Policy

1 Introduction

369jl ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of every player who uses our online gaming and sports betting services. This Privacy Policy has been prepared in accordance with applicable Philippine data protection law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy describes the types of personal information we collect from players and visitors to the 369jl platform, the purposes for which that information is used, the circumstances under which it may be shared with third parties, and the rights available to you as a data subject under Philippine law.

We encourage you to read this document in full. If you have questions about any part of this Privacy Policy, you may contact our Data Protection Officer using the details provided in Section 14.

2 Data Controller

For the purposes of this Privacy Policy, 369jl acts as the personal information controller in respect of the personal data collected through the Platform. This means that 369jl determines the purposes and means by which your personal data is processed.

Where 369jl engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, or analytics platforms — those parties act as personal information processors and are contractually bound to process your data only in accordance with 369jl's instructions and applicable law.

3 Data We Collect

369jl collects the following categories of personal data from players and platform visitors:

369jl does not collect sensitive personal information beyond what is strictly necessary for identity verification, regulatory compliance, and responsible gaming purposes. We do not collect biometric data beyond what is submitted voluntarily as part of the KYC process.

4 How We Collect Your Data

369jl collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 8 for more detail on cookies.
• Third-Party Sources: Identity and fraud-check data received from licensed identity verification providers, payment processors, and, where applicable, regulatory databases. 369jl only receives data from third parties where there is a lawful basis for doing so.
• Device Permissions: If you use the 369jl mobile application, certain device permissions (such as camera access for document scanning during KYC) may be requested. These permissions are optional and can be managed through your device settings.

5 How We Use Your Data

369jl uses the personal data it collects for the following purposes:

• Account Management: To create, maintain, and administer your 369jl player account, including processing deposits, withdrawals, and bonus claims.
• Transaction Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels, and to maintain accurate financial records.
• Transaction Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels, and to maintain accurate financial records.
• Customer Support: To respond to your inquiries, resolve complaints, and provide technical assistance through our live chat and email support channels.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct on the Platform.
• Responsible Gaming: To monitor gaming patterns, identify players who may be at risk of problem gambling, and administer responsible gaming tools such as deposit limits and self-exclusion.
• Legal and Regulatory Compliance: To comply with applicable Philippine laws, regulatory requirements, court orders, and lawful requests from government authorities.
• Platform Improvement: To analyze usage patterns, conduct internal research, and improve the features, performance, and user experience of the 369jl platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time through your account settings.

369jl will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, 369jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing that is necessary to perform our contract with you — including account registration, transaction processing, and customer support — is carried out on the basis of contractual necessity.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and regulatory reporting, is carried out on the basis of legal obligation.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics is carried out on the basis of 369jl's legitimate interests, provided those interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and certain optional data collection activities is carried out on the basis of your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing and Disclosure

369jl does not sell, rent, or trade your personal data to third parties for their own marketing 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:

• Payment Processors: Licensed payment service providers facilitating deposits and withdrawals, including GCash, PayMaya, and partner banks such as BPI, BDO, and Metrobank. These providers receive only the data necessary to process your transaction.
• Identity Verification Providers: Third-party KYC and AML screening services engaged to verify player identities and screen against regulatory watchlists.
• Technology and Infrastructure Providers: Cloud hosting, content delivery, and platform infrastructure providers who process data on 369jl's behalf under strict data processing agreements.
• Customer Support Tools: Live chat and ticketing platform providers used to deliver customer support services.
• Regulatory and Law Enforcement Authorities: Government agencies, regulators, courts, and law enforcement bodies where disclosure is required by applicable Philippine law or a valid legal order.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by 369jl, subject to professional confidentiality obligations.

All third-party processors engaged by 369jl are contractually required to implement appropriate technical and organizational security measures and to process personal data only in accordance with 369jl's documented instructions.

8 Cookies and Tracking Technologies

369jl uses cookies and similar tracking technologies on its website and mobile application to enhance your experience, maintain session security, and gather analytics data. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. They cannot be disabled without affecting core Platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players interact with the Platform, helping us identify areas for improvement. This data does not identify you personally.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the Platform.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 369jl Platform. 369jl does not use third-party advertising cookies or cross-site tracking technologies for the purpose of serving targeted advertisements on external platforms.

9 Data Retention

369jl retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and Transaction Records: Retained for a minimum of five (5) years following account closure, in accordance with Philippine AML record-keeping requirements.
• KYC and Identity Verification Documents: Retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later.
• Customer Support Communications: Retained for two (2) years from the date of the last interaction, unless a longer retention period is required for ongoing dispute resolution or legal proceedings.
• Technical and Usage Logs: Retained for up to twelve (12) months, after which they are anonymized or deleted.
• Marketing Consent Records: Retained for the duration of your account and for three (3) years following account closure, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 369jl's data disposal procedures.

10 Data Security

369jl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 369jl Platform.
• Encryption of sensitive data at rest, including financial records and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for the detection, containment, and notification of personal data breaches in accordance with NPC requirements.

While 369jl takes all reasonable steps to protect your data, no electronic transmission or storage system is entirely immune to risk. Players are encouraged to use strong, unique passwords for their 369jl accounts and to report any suspected unauthorized access to customer support immediately.

11 Your Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 369jl:

• Right to Be Informed: The right to be informed about how your personal data is collected and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data 369jl holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held about you. You may update certain account details directly through your account settings.
• 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 369jl's 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 a copy of your personal data in a structured, commonly used, machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 14. 369jl will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

12 Children and Minors

The 369jl Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. 369jl does not knowingly collect personal data from individuals under the age of 21.

If 369jl becomes aware that personal data has been collected from a person under the age of 21, the relevant account will be immediately suspended, all associated data will be reviewed, and the data will be deleted or returned to the extent required by law. Any deposits made by underage players will be returned to the payment source where technically feasible, and any winnings will be forfeited.

If you believe that a minor has registered on the 369jl Platform, please contact our customer support team immediately so that appropriate action can be taken.

13 Changes to This Policy

369jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. When material changes are made, we will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this document. We encourage you to review this Privacy Policy periodically to stay informed about how 369jl protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 369jl, please contact our Data Protection Officer through any of the following channels:

• Live Chat: Available 24/7 through the 369jl Platform interface — the fastest way to reach our support team.
• Email: [email protected] — please include "Privacy Request" in the subject line for data-related inquiries.

369jl aims to acknowledge all privacy-related inquiries within one (1) business day and to provide a substantive response within fifteen (15) business days. For complex requests, we may require additional time and will notify you accordingly.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. Information about the NPC and how to file a complaint is available through official Philippine government channels.