396jl Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") applies to all personal data collected and processed by 396jl ("396jl", "we", "us", "our") in connection with the operation of the online gaming platform accessible at 396jl.org (the "Platform").

1.2 This Policy should be read together with 396jl's Terms & Conditions and Responsible Gaming Policy. Terms defined in the Terms & Conditions and not otherwise defined herein carry the same meaning in this Policy.

1.3 396jl operates in the Philippines and processes personal data in compliance with Republic Act No. 10173, known as the Data Privacy Act of 2012 ("DPA"), and its implementing rules and regulations as issued by the National Privacy Commission ("NPC").

2. Data Controller

2.1 For the purposes of the DPA, 396jl acts as the Personal Information Controller in respect of the personal data it collects and processes from players registered on the Platform.

2.2 All inquiries, requests, and complaints regarding the processing of your personal data should be directed to the 396jl Data Protection Officer using the contact details set out in Section 16 of this Policy.

3. Categories of Personal Data We Collect

3.1 396jl collects the following categories of personal data from players:

Identity & Registration Data

• Full legal name as it appears on a valid Philippine government-issued ID;
• Date of birth (for age verification — 396jl requires players to be aged 21 or older);
• Registered Philippine mobile number;
• Username and encrypted password;
• Gender and residential address.

KYC & Verification Documents

• Copies of valid Philippine government-issued identification (e.g., PhilSys National ID, passport, driver's licence, UMID, voter's ID, SSS/GSIS ID);
• Proof of address documents where required;
• Proof of payment method (e.g., GCash account name confirmation, bank account details).

Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method identifiers;
• Account wallet balance history;
• Bonus and promotion redemption records.

Gaming Activity Data

• Records of games played, bets placed, outcomes, and session durations;
• Sports betting selections and wager history;
• Responsible gaming limit settings and self-exclusion records.

Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Pages visited, features accessed, and time spent on the Platform;
• Cookies and similar tracking technology data (see Section 11).

Communications Data

• Records of live chat, email, and other communications with the 396jl support team;
• Survey responses and feedback submissions.

4. How We Collect Your Data

4.1 Directly from you — when you register a 396jl account, complete KYC verification, make a deposit or withdrawal, interact with customer support, or submit any form on the Platform.

4.2 Automatically — when you access and use the Platform, through cookies, web analytics tools, server logs, and similar technologies that record technical and usage data.

4.3 From third parties — from payment processors such as GCash and Maya for transaction verification purposes; from KYC and identity verification service providers; and from fraud detection and anti-money-laundering screening services.

5. Purposes of Processing

5.1 396jl processes your personal data for the following purposes:

• Account Management: To create, maintain, and operate your 396jl player account;
• Age Verification: To confirm that you are at least 21 years of age, as required by Philippine gaming regulations;
• KYC Compliance: To verify your identity as required by applicable anti-money-laundering and counter-terrorism financing laws;
• Payment Processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other supported payment methods;
• Service Provision: To provide access to games, betting markets, promotions, and other Platform features;
• Fraud Prevention & Security: To detect and prevent fraud, money laundering, account compromise, and other illegal activity;
• Responsible Gaming: To monitor gaming activity and apply responsible gaming tools, limits, and interventions where appropriate;
• Legal & Regulatory Compliance: To comply with applicable Philippine laws, regulatory directives, and lawful requests from government authorities;
• Customer Support: To respond to your inquiries and resolve complaints;
• Platform Improvement: To analyse usage patterns and improve the performance, design, and features of the 396jl Platform;
• Marketing Communications: To send you promotional offers and updates, where you have provided your consent to receive such communications.

6. Legal Basis for Processing

6.1 396jl processes your personal data on the following legal bases under the DPA:

• Contractual Necessity: Processing necessary for the performance of your account agreement with 396jl, including account management, payment processing, and service delivery;
• Legal Obligation: Processing required to comply with KYC, anti-money-laundering, tax reporting, and other legal obligations under Philippine law;
• Legitimate Interests: Processing for fraud prevention, platform security, and improving the Platform, where such interests are not overridden by your rights;
• Consent: Processing for marketing communications, where you have provided explicit consent. You may withdraw this consent at any time by contacting 396jl support.

7. Data Sharing & Disclosure

7.1 396jl does not sell, rent, or trade your personal data to third-party advertisers or data brokers.

7.2 396jl may share your personal data with the following categories of third parties:

• Payment Service Providers: GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), BPI, BDO, Metrobank, and other payment processors, for the purpose of processing your transactions;
• KYC & Identity Verification Providers: Third-party identity verification and document authentication services used to fulfil regulatory KYC requirements;
• Fraud & AML Screening Services: Providers of fraud detection, transaction monitoring, and anti-money-laundering screening tools;
• Technology & Infrastructure Providers: Cloud hosting, data storage, cybersecurity, and platform technology vendors who process data on 396jl's behalf under appropriate data processing agreements;
• Game Software Providers: Game studios and providers whose titles are available on the 396jl Platform may receive limited gameplay data necessary to operate their game systems;
• Regulatory & Law Enforcement Authorities: Philippine government agencies, including the NPC, relevant gaming regulatory authorities, the Anti-Money Laundering Council (AMLC), and law enforcement, where required by applicable law or in response to a lawful legal process.

8. International Data Transfers

8.1 Some of 396jl's third-party service providers are located outside the Philippines. Where personal data is transferred to recipients in other countries, 396jl takes appropriate measures to ensure that such transfers comply with the DPA, including entering into data sharing agreements that provide an equivalent level of data protection.

9. Data Retention

9.1 396jl retains your personal data for as long as your account remains active and for such further period as may be required to comply with applicable legal and regulatory obligations. In particular:

• KYC and identity documents are retained for a minimum of five (5) years following account closure, as required by applicable anti-money-laundering regulations;
• Financial transaction records are retained for a minimum of five (5) years;
• Gaming activity records are retained for a minimum of three (3) years;
• Marketing consent records are retained for the duration of your account and for one (1) year following withdrawal of consent.

9.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised.

10. Security Measures

10.1 396jl implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 396jl Platform;
• Encryption of sensitive data at rest, including passwords (which are stored in hashed form and never in plain text);
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Incident response procedures for data breach identification and reporting.

10.2 In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 396jl will notify the NPC and affected players in accordance with the requirements of the DPA.

11. Cookies & Tracking Technologies

11.1 The 396jl Platform uses cookies and similar tracking technologies to facilitate your use of the Platform, remember your preferences, analyse traffic and usage patterns, and support fraud prevention functions.

11.2 The types of cookies used on the 396jl Platform include:

• Strictly Necessary Cookies: Essential for the operation of the Platform, including session authentication and security functions. These cannot be disabled.
• Functional Cookies: Remember your preferences and settings to improve your experience on return visits.
• Analytics Cookies: Collect aggregated, anonymised data about how players interact with the Platform to help 396jl improve its design and performance.

11.3 You may control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the 396jl Platform.

12. Your Data Rights

12.1 Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 396jl:

• Right to be Informed: The right to be informed that your data is being collected and processed;
• Right of Access: The right to obtain a copy of the personal data 396jl holds about you;
• Right to Rectification: The right to have inaccurate or incomplete data corrected;
• Right to Erasure: The right to request deletion of your personal data, subject to 396jl's legal retention obligations;
• Right to Object: The right to object to certain types of processing, including direct marketing;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission at privacy.gov.ph if you believe 396jl has not handled your personal data lawfully.

12.2 To exercise any of these rights, please contact the 396jl Data Protection Officer using the details in Section 16. 396jl will respond to valid requests within thirty (30) days.

13. Marketing Communications

13.1 With your consent, 396jl may send you promotional communications about bonuses, new game releases, sports betting promotions, and other 396jl offers via SMS or email.

13.2 You may opt out of marketing communications at any time by contacting 396jl customer support or by following the unsubscribe instructions in any marketing message. Opting out of marketing communications will not affect the operational and transactional communications 396jl sends in connection with your account.

14. Minors

14.1 The 396jl Platform is strictly prohibited for use by persons under the age of twenty-one (21) years. 396jl does not knowingly collect personal data from persons under 21. If 396jl discovers that personal data has been collected from an underage individual, the account will be immediately suspended and the personal data deleted or anonymised.

14.2 If you are a parent or guardian and believe that a person under 21 in your care has registered a 396jl account, please contact 396jl support immediately using the details in Section 16.

15. Updates to This Privacy Policy

15.1 396jl reserves the right to update this Privacy Policy at any time. The updated Policy will be posted on the Platform with the revised effective date. Where changes are material, 396jl will provide notice to registered players via SMS or Platform notification at least seven (7) days before the changes take effect.

15.2 Your continued use of the 396jl Platform after the effective date of any updated Policy constitutes your acceptance of the changes.

16. Contact the 396jl Data Protection Officer

16.1 If you have questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how 396jl handles your personal data, please contact us:

• Email: [email protected]
• Live Chat: Available 24/7 within the 396jl Platform (login required)
• Response Time: 396jl aims to respond to all data-related requests within thirty (30) calendar days