3jl6 Privacy Policy

This Privacy Policy ("Policy") describes how 3jl6 ("3jl6", "we", "us", "our") collects, processes, stores, shares, and protects personal data about individuals ("you", "player", "user") who access or use the 3jl6 online gaming platform at 3jl6.co and all associated subdomains, mobile interfaces, and related services (collectively, the "Platform").

This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations ("IRR"), and in conjunction with 3jl6's obligations under the Philippine Amusement and Gaming Corporation's ("PAGCOR") regulatory framework, including applicable Anti-Money Laundering ("AML") requirements.

By registering on or continuing to use the 3jl6 Platform, you acknowledge that you have read, understood, and consent to the collection and processing of your personal data as described in this Policy. If you do not agree with the terms of this Policy, please discontinue your use of the Platform.

Data Controller: 3jl6 (operating the Platform at 3jl6.co) is the personal information controller ("PIC") responsible for the processing of your personal data as described in this Policy.

Regulatory Oversight: 3jl6 operates under PAGCOR regulatory authorization in the Philippines. As a PAGCOR-regulated operator, 3jl6 is additionally subject to data processing obligations arising from its gaming license conditions, which include mandatory KYC and AML data collection and reporting requirements.

Data Protection Officer (DPO): 3jl6 has designated a Data Protection Officer responsible for overseeing compliance with the Data Privacy Act. You may contact the DPO for privacy-related concerns using the contact details provided in Section 15 of this Policy.

3jl6 collects the following categories of personal data in the course of operating the Platform and fulfilling its regulatory obligations:

3jl6 does not intentionally collect sensitive personal information (as defined under the DPA, including health, political views, or religious beliefs) unless specifically required for KYC compliance purposes (e.g., a medical certificate in connection with a responsible gaming self-exclusion request).

3jl6 collects your personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, submit a responsible gaming request, or update your account settings.
• Automatically through the Platform: When you access or use the 3jl6 Platform, technical data (including IP address, device identifiers, and session data) is automatically logged by our servers and analytics systems. See Section 7 for details on cookies and tracking technologies.
• From third-party payment providers: When you transact via GCash, Maya, BPI, BDO, or other supported payment channels, 3jl6 receives transaction confirmation data (amount, reference number, timestamp) from the relevant payment processor. We do not receive your full payment account passwords or PINs.
• From identity verification service providers: During enhanced KYC processes, identity verification data may be cross-referenced with government databases or third-party KYC service providers operating under their own PAGCOR and NPC-compliant data handling frameworks.
• From PAGCOR and law enforcement (where applicable): In certain circumstances, 3jl6 may receive information from PAGCOR or Philippine law enforcement authorities in connection with AML investigations or player protection measures.

3jl6 processes your personal data on the following legal bases and for the following purposes:

• Performance of a Contract: Processing necessary to provide the gaming services you have contracted for — including account management, game access, payment processing, and customer support.
• Legal Obligation: Processing required to comply with PAGCOR's licensing conditions, the Anti-Money Laundering Act (Republic Act No. 9160, as amended), KYC requirements, tax obligations, and mandatory reporting to Philippine regulatory authorities.
• Legitimate Interests: Processing for fraud detection and prevention, platform security monitoring, responsible gaming analytics, and internal business reporting — where such interests are not overridden by your privacy rights.
• Consent: Where 3jl6 sends you promotional materials, personalized offers, or marketing communications, we do so on the basis of your consent, which you may withdraw at any time via your account settings or by contacting support.

3jl6 does not sell, rent, or trade your personal data. We share personal data with third parties only in the following circumstances and for the following purposes:

• Payment Processors: GCash (Mynt), Maya (PayMaya Philippines), BPI, BDO, Metrobank, and other payment service providers — for the purpose of processing deposits and withdrawals. These providers operate under their own privacy policies and applicable BSP regulations.
• Identity Verification Providers: Third-party KYC service providers used to verify government-issued IDs and confirm player identity during enhanced due diligence procedures.
• Game Content Providers: Licensed game providers (such as JILI, PG Soft, Pragmatic Play) may receive anonymized session and performance data for the purpose of game optimization and bug resolution. These providers do not receive personally identifiable information.
• PAGCOR and Philippine Regulatory Authorities: As required by our gaming license conditions — including mandatory transaction reporting and player data disclosures required under AML law.
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports and covered transaction reports as mandated by Republic Act No. 9160 (as amended by Republic Act No. 10365).
• Law Enforcement and Courts: Where disclosure is required by a valid court order, subpoena, or lawful request from a Philippine government authority.
• Professional Advisers: Legal, accounting, and auditing firms advising 3jl6, subject to confidentiality obligations.

All third parties with whom 3jl6 shares personal data are required to maintain appropriate technical and organizational safeguards and to process your data only for the specified purpose and in accordance with applicable Philippine law.

The 3jl6 Platform uses cookies and similar tracking technologies to provide a functional, secure, and personalized experience. Cookies are small text files stored on your device by your browser when you visit the Platform.

7.1 Essential Cookies. These cookies are strictly necessary for the operation of the Platform — including maintaining your login session, remembering your wallet balance between pages, and preventing cross-site request forgery attacks. Essential cookies cannot be disabled without breaking core platform functionality.

7.2 Analytics Cookies. 3jl6 uses analytics tools to understand how players navigate the Platform — including which games are most visited, where users experience errors, and how long sessions last. This data is used in aggregate and anonymized form to improve the Platform. You may opt out of analytics cookies via your browser settings.

7.3 Functional Cookies. These cookies remember your preferences — such as your preferred game lobby view, language settings, and responsible gaming tool configurations — so you don't have to reconfigure them on every visit.

7.4 Session Security Cookies. Short-lived session cookies used to authenticate your identity during an active login session. These expire when you log out or close your browser.

You can manage or disable cookies through your browser settings at any time. Please note that disabling essential cookies will impair your ability to use the 3jl6 Platform.

3jl6 retains personal data for as long as necessary to fulfil the purposes outlined in this Policy, including compliance with legal, regulatory, and PAGCOR requirements.

• Active Account Data: Retained for the duration of your active account relationship with 3jl6.
• Closed Account Data: Following account closure, 3jl6 retains identity, KYC, and financial transaction data for a minimum period of five (5) years as required under the Anti-Money Laundering Act and PAGCOR record-keeping requirements.
• Gaming Activity Logs: Retained for a minimum of five (5) years for PAGCOR compliance and dispute resolution purposes.
• Support Communications: Retained for a minimum of three (3) years for quality assurance and dispute evidence purposes.
• Technical/Session Logs: Retained for a maximum of twelve (12) months unless required for an ongoing security investigation.
• Marketing Preferences: Retained until you withdraw consent or request deletion, after which your opt-out preference record is maintained permanently to prevent re-contact.

After the applicable retention period has elapsed, personal data is securely deleted or anonymized in a manner that prevents re-identification.

3jl6 implements technical and organizational security measures appropriate to the nature and sensitivity of the personal data it processes. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and 3jl6's servers;
• Encryption of sensitive data fields (including passwords, stored using one-way cryptographic hash functions) within 3jl6's databases;
• Access controls and role-based permissions on internal systems containing personal data, limiting access to authorized personnel only;
• Comprehensive audit logging of access to systems containing personal data;
• Regular security vulnerability assessments and penetration testing;
• Incident response procedures designed to detect, contain, and notify affected players and the NPC of any personal data breach within the timeframes required by the DPA;
• Physical security controls at data processing facilities.

Under the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 3jl6:

• Right to be Informed: You have the right to be informed of how your personal data is being processed by 3jl6 — this Policy serves as 3jl6's primary disclosure.
• Right of Access: You may request a copy of the personal data 3jl6 holds about you, together with information about how it has been processed.
• Right to Rectification: If your personal data held by 3jl6 is inaccurate or incomplete, you have the right to request correction. You may update many details directly through your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where there is no legal basis for continued retention. Please note that erasure requests are subject to 3jl6's mandatory retention obligations under PAGCOR and AML regulations, which take precedence over erasure requests in many cases.
• Right to Data Portability: You may request a copy of your personal data in a commonly used, machine-readable format.
• Right to Object: You may object to processing of your personal data for marketing purposes at any time. You may also object to processing based on legitimate interests grounds, subject to 3jl6's assessment of overriding legal obligations.
• Right to File a Complaint: If you believe your data privacy rights have been violated, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please submit a written request to 3jl6's Data Protection Officer using the contact details in Section 15. 3jl6 will acknowledge your request within five (5) business days and provide a substantive response within fifteen (15) business days, or as otherwise required by the DPA.

The 3jl6 Platform is strictly prohibited for use by individuals under the age of 21, as required by PAGCOR regulations. 3jl6 does not knowingly collect personal data from individuals under this age threshold.

If 3jl6 becomes aware that personal data has been collected from an individual below 21 years of age, the associated account will be suspended immediately, all data will be deleted in accordance with the DPA (subject to any PAGCOR-mandated reporting obligations triggered by the incident), and the matter will be reported to PAGCOR's compliance division.

If you have reason to believe that a minor has registered on the 3jl6 Platform, please notify us immediately at [email protected].

3jl6 processes certain personal data specifically in connection with its responsible gaming obligations under PAGCOR's regulatory framework. This processing is necessary to fulfil 3jl6's legal obligations as a licensed gaming operator and to protect the welfare of players.

Responsible gaming-related data processing includes:

• Maintaining records of voluntary deposit limits, session time limits, cool-off periods, and self-exclusion requests set by players;
• Monitoring player gaming activity patterns to identify potential indicators of problem gambling behavior, as required by PAGCOR's responsible gaming standards;
• Maintaining self-exclusion lists and ensuring excluded players cannot access the Platform during the exclusion period;
• Processing self-exclusion requests submitted to PAGCOR's national exclusion register, where applicable.

Responsible gaming data is treated with the highest sensitivity and is accessible only to authorized 3jl6 compliance personnel. This data is retained for the full mandatory retention period under PAGCOR regulations, even following account closure.

In the course of operating the Platform, certain personal data may be transferred to and processed by third-party service providers located outside the Republic of the Philippines — for example, game content providers, cloud hosting infrastructure providers, or fraud detection services with processing operations abroad.

Where such cross-border transfers occur, 3jl6 ensures that appropriate safeguards are in place, including:

• Entering into data processing agreements with third-party processors that require data protection standards equivalent to those required by the Philippine DPA;
• Transferring data only to countries that have been assessed to provide an adequate level of data protection;
• Applying additional encryption and access controls to data transferred cross-border.

Cross-border transfers are conducted strictly within the parameters permitted by the NPC's regulations on personal data transfers outside the Philippines.

3jl6 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or applicable law. The "Last Updated" date at the top of this Policy will reflect the date of any amendment.

For material changes — meaning changes that significantly affect how we process your personal data or your rights under this Policy — 3jl6 will provide advance notice via email to your registered account address and/or via a prominent notice on the Platform, no less than fourteen (14) days prior to the amended Policy taking effect.

Your continued use of the 3jl6 Platform after the effective date of any amendment constitutes your acknowledgment of the updated Policy. We recommend reviewing this page periodically to stay informed of how 3jl6 handles your personal data.

For all privacy-related inquiries, data subject rights requests, or concerns about how 3jl6 handles your personal data, please contact our Data Protection Officer through the following channels:

• Data Protection Officer Email: [email protected] (Subject line: "Data Privacy Request")
• General Support Email: [email protected]
• Live Chat: Available 24/7 from within your logged-in 3jl6 account dashboard
• Support Hours: 24 hours a day, 7 days a week, Philippine Standard Time (PST / UTC+8)

If you are not satisfied with 3jl6's response to your data privacy concern, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines, the independent government body responsible for overseeing enforcement of the Data Privacy Act of 2012.