Contents
1. Introduction
3jl3 ("3jl3", "we", "us", "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the 3jl3 platform at https://3jl3.org (the "Platform") and all associated services (collectively, the "Services"). This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information in connection with your use of the Services.
This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. It should be read together with our Terms & Conditions and Responsible Gaming Policy.
By registering an account on 3jl3 or otherwise using the Services, you acknowledge that you have read and understood this 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 immediately.
2. Data Controller
For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, 3jl3 acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes in connection with the Services.
As Personal Information Controller, 3jl3 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable data privacy laws and this Policy.
Where 3jl3 engages third-party service providers to process personal data on its behalf (for example, payment processors, game providers, or identity verification services), those third parties act as Personal Information Processors (PIPs) and are contractually bound to process personal data only in accordance with 3jl3's instructions and applicable law.
3. Personal Data We Collect
3jl3 collects the following categories of personal data in connection with the operation of the Platform and the provision of the Services:
3.1 Identity & Contact Data
- Full legal name (first name, middle name, last name)
- Date of birth and age verification information
- Gender
- Nationality and country of residence
- Residential address (barangay, city/municipality, province, ZIP code)
- Mobile number and email address
3.2 Identity Verification (KYC) Data
- Government-issued photo identification (PhilSys National ID, passport, driver's license, UMID, SSS ID, or equivalent)
- Proof of address documents (utility bill, bank statement, barangay certificate)
- Selfie or liveness check images submitted for identity verification purposes
- Source of funds documentation where required by anti-money laundering regulations
3.3 Financial & Transaction Data
- GCash or Maya account details (registered mobile number and account name)
- Bank account details (account name, account number, bank name) for bank transfer transactions
- Debit card details (card number masked, expiry date, cardholder name)
- Deposit and withdrawal transaction history, including amounts, dates, and payment methods
- Account balance and bonus balance information
3.4 Gaming & Activity Data
- Game history, including games played, wagers placed, outcomes, and winnings
- Bonus and promotion participation history
- Session duration, login timestamps, and activity logs
- Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
- Customer support interactions and complaint records
3.5 Technical & Device Data
- IP address and approximate geolocation derived from IP
- Device type, operating system, and browser type and version
- Unique device identifiers
- Cookie identifiers and similar tracking technology data (see Section 9)
- Referring URL and pages visited on the Platform
4. How We Collect Your Data
3jl3 collects personal data through the following means:
- Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions
- Automated collection: Technical and device data collected automatically when you access the Platform, including through cookies, web beacons, and similar tracking technologies
- Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment confirmation data from payment processors such as GCash, Maya, and partner banks
- Regulatory sources: Self-exclusion and player protection data from PAGCOR or other recognized gaming regulatory authorities
5. Purpose & Legal Basis for Processing
3jl3 processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:
| Purpose | Data Categories Used | Legal Basis |
|---|---|---|
| Account registration and management | Identity, contact | Performance of contract |
| Age and identity verification (KYC) | Identity, KYC documents | Legal obligation; legitimate interest |
| Processing deposits and withdrawals | Financial, transaction | Performance of contract |
| Anti-money laundering (AML) compliance | Identity, financial, transaction | Legal obligation |
| Fraud prevention and security | Identity, technical, gaming | Legitimate interest; legal obligation |
| Responsible gaming monitoring | Gaming, activity | Legal obligation; legitimate interest |
| Customer support and complaints | Identity, contact, gaming | Performance of contract |
| Bonus and promotion administration | Identity, gaming, transaction | Performance of contract |
| Platform analytics and improvement | Technical, gaming, activity | Legitimate interest |
| Marketing communications (where consented) | Identity, contact | Consent |
| Regulatory reporting to PAGCOR | Identity, financial, gaming | Legal obligation |
6. Sharing Your Personal Data
3jl3 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:
- Payment processors: GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to facilitate deposits and withdrawals
- Identity verification providers: Third-party KYC and AML screening services engaged to verify your identity and comply with regulatory obligations
- Game providers: Software providers whose games are available on the 3jl3 platform, to the extent necessary to deliver game services and resolve disputes
- Regulatory authorities: PAGCOR and other competent Philippine government agencies where disclosure is required by law, court order, or regulatory direction
- Law enforcement: Philippine law enforcement agencies where disclosure is required in connection with the investigation or prosecution of criminal activity, including fraud and money laundering
- IT and infrastructure providers: Cloud hosting, cybersecurity, and platform maintenance service providers who process data solely on 3jl3's instructions
- Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations
All third-party recipients are required to handle your personal data in accordance with applicable data privacy laws and are prohibited from using your data for any purpose other than the specific purpose for which it was shared.
7. Data Retention
3jl3 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account and identity data | Duration of account + 5 years after closure | AML / PAGCOR regulatory requirement |
| KYC verification documents | Duration of account + 5 years after closure | Legal obligation (RA 9160 as amended) |
| Financial transaction records | Duration of account + 5 years after closure | AML / tax / regulatory requirement |
| Gaming activity logs | Duration of account + 2 years after closure | Dispute resolution; regulatory audit |
| Customer support records | 3 years from last interaction | Legitimate interest; legal claims |
| Marketing consent records | Until consent withdrawn + 1 year | Proof of consent |
| Technical / device logs | 13 months from collection | Security; fraud prevention |
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 3jl3's data disposal procedures. Where data is anonymized, the resulting information is no longer personal data and may be retained indefinitely for analytical purposes.
8. Data Security
3jl3 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:
- Encryption: All data transmitted between your device and the 3jl3 platform is encrypted using TLS (Transport Layer Security). Sensitive data at rest, including financial account details and KYC documents, is encrypted using industry-standard encryption algorithms.
- Access controls: Access to personal data is restricted to authorized 3jl3 personnel and service providers on a strict need-to-know basis. All access is logged and audited.
- Two-factor authentication: 3jl3 supports and encourages the use of two-factor authentication (2FA) for player accounts to reduce the risk of unauthorized access.
- Penetration testing: The 3jl3 platform undergoes regular security assessments and penetration testing by qualified cybersecurity professionals.
- Incident response: 3jl3 maintains a data breach response plan and will notify affected individuals and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012 in the event of a personal data breach.
9. Cookies & Tracking Technologies
3jl3 uses cookies and similar tracking technologies to operate and improve the Platform, personalize your experience, and analyze usage patterns. The following types of cookies are used:
- Strictly necessary cookies: Essential for the Platform to function correctly, including session management, authentication, and security. These cookies cannot be disabled.
- Functional cookies: Remember your preferences and settings (such as language and display preferences) to provide a more personalized experience.
- Analytics cookies: Collect aggregated, anonymized data about how visitors use the Platform to help us understand usage patterns and improve the Services.
- Marketing cookies: Used to deliver relevant promotional content to you based on your interests and activity on the Platform, where you have consented to receive marketing communications.
You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the Services.
10. Your Data Privacy Rights
Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by 3jl3:
- Right to be informed: You have the right to be informed of how your personal data is collected, used, stored, and shared, as set out in this Policy.
- Right of access: You have the right to request a copy of the personal data 3jl3 holds about you, together with information about how it is processed.
- Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held by 3jl3.
- Right to erasure: You have 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 and regulatory retention obligations.
- Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interest.
- Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
- Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.
To exercise any of the above rights, please contact 3jl3's Data Protection Officer (DPO) using the contact details provided in Section 15. 3jl3 will respond to all verified data subject requests within thirty (30) days of receipt, or within such extended period as permitted by applicable law.
11. Minors & Age Restriction
The 3jl3 platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 3jl3 does not knowingly collect personal data from individuals under the age of 21.
If 3jl3 becomes aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be returned to the payment source after deduction of any applicable processing fees.
If you are a parent or guardian and believe that your child under the age of 21 has registered an account on 3jl3 or provided personal data to us, please contact our customer support team immediately so that we can take appropriate action.
12. Cross-Border Data Transfers
3jl3 primarily processes personal data within the Republic of the Philippines. However, certain service providers engaged by 3jl3 โ including cloud infrastructure providers, game software providers, and identity verification services โ may process personal data in jurisdictions outside the Philippines.
Where personal data is transferred outside the Philippines, 3jl3 ensures that appropriate safeguards are in place to protect your data, including:
- Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law
- Transfers only to jurisdictions that have been assessed as providing an adequate level of data protection
- Binding corporate rules where applicable
By using the 3jl3 platform, you consent to the transfer of your personal data to third-party service providers located outside the Philippines, subject to the safeguards described above.
13. Third-Party Links & Services
The 3jl3 platform may contain references to third-party services, including payment providers and game software providers. This Policy applies only to personal data collected and processed by 3jl3 in connection with the Platform and Services. 3jl3 is not responsible for the privacy practices of third-party services, and we encourage you to review the privacy policies of any third-party services you interact with.
14. Changes to This Policy
3jl3 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, 3jl3 will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect. The "Last Updated" date at the top of this page will be revised accordingly.
Your continued use of the 3jl3 platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. We recommend reviewing this Policy periodically to stay informed of how 3jl3 protects your personal data.
15. Contact Us & Data Protection Officer
3jl3 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Policy. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO:
- Data Protection Officer: 3jl3 Privacy Office
- Email: [email protected]
- General Support: [email protected]
- Live Chat: Available 24/7 via the chat widget on the 3jl3 platform
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 not been adequately addressed by 3jl3.