Privacy Policy

1. Introduction

3jl1 ("the Company," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who access or use the 3jl1 platform ("the Platform"), available at https://3jl1.net. This Privacy Policy ("Policy") describes how we collect, use, store, disclose, and protect personal information in connection with your use of the Platform.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines. Where applicable, this Policy also reflects the principles of internationally recognized data protection frameworks.

This Policy applies to all registered players, visitors, and any other individuals whose personal data is processed by 3jl1 in connection with the Platform. It should be read together with our Terms & Conditions, which govern your use of the Platform.

2. Personal Data We Collect

3jl1 collects personal data in the following categories, depending on how you interact with the Platform:

2.1 Data You Provide Directly

• Registration data: Full legal name, date of birth, gender, nationality, residential address, email address, and mobile number.
• Identity verification (KYC) data: Government-issued identification documents (e.g., Philippine passport, driver's license, PhilSys National ID, UMID, SSS ID), proof of address documents, and selfie photographs where required.
• Payment data: GCash account details, PayMaya (Maya) account details, bank account information (BPI, BDO, Metrobank), and transaction history. Note: 3jl1 does not store full card numbers or banking credentials directly — these are handled by our regulated payment processing partners.
• Communications data: Messages, emails, and chat transcripts exchanged with our customer support team.
• Responsible gaming data: Deposit limits, self-exclusion requests, and cooling-off period preferences you set through your account.

2.2 Data Collected Automatically

• Technical data: IP address, device type, operating system, browser type and version, screen resolution, and unique device identifiers.
• Usage data: Pages visited, games played, session duration, click patterns, wagering history, and platform navigation behavior.
• Location data: General geographic location derived from your IP address, used to verify jurisdictional eligibility.
• Cookie and tracking data: Information collected through cookies, web beacons, and similar technologies as described in Section 8 of this Policy.

2.3 Data from Third Parties

We may receive personal data about you from third-party sources, including:

• Identity verification and KYC service providers
• Payment processors and e-wallet providers (e.g., GCash, PayMaya)
• Fraud detection and anti-money laundering screening services
• Regulatory authorities, including PAGCOR, where required by law

Data Category	Examples	Source
Identity Data	Name, date of birth, government ID	You / KYC provider
Contact Data	Email, mobile number, address	You
Financial Data	GCash/PayMaya account, bank details	You / Payment processor
Technical Data	IP address, device ID, browser	Automatically collected
Usage Data	Games played, session logs, wager history	Automatically collected
Communications Data	Support chat transcripts, emails	You

3. How We Use Your Personal Data

3jl1 uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and administer your 3jl1 player account, including processing your registration and verifying your identity.
• Transaction processing: To process deposits and withdrawals in Philippine Peso (₱) through your chosen payment method, and to maintain accurate financial records.
• Legal and regulatory compliance: To fulfill our obligations under Philippine law, including anti-money laundering (AML) requirements, PAGCOR compliance obligations, and the Data Privacy Act of 2012. This includes conducting KYC verification and filing mandatory reports with relevant authorities.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct on the Platform.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible gaming: To monitor gaming behavior, enforce self-exclusion and deposit limit requests, and identify players who may be at risk of problem gambling.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the 3jl1 Platform.
• Marketing communications: To send you promotional offers, bonuses, 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.
• Legal claims: To establish, exercise, or defend legal claims in connection with your use of the Platform.

4. Legal Basis for Processing

3jl1 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between you and 3jl1 — specifically, to operate your account, process transactions, and deliver the services you have registered for.
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML obligations, PAGCOR licensing requirements, and tax reporting duties.
• Legitimate interests: Processing is necessary for 3jl1's legitimate business interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as marketing communications and non-essential cookies — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Sharing Your Personal Data

3jl1 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 service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory requirements.
• Technology and infrastructure providers: Cloud hosting, data storage, and platform technology providers who process data on our behalf under strict contractual data processing agreements.
• Customer support providers: Third-party customer service platforms used to manage support tickets and live chat interactions.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or court order.
• Professional advisers: Lawyers, auditors, and accountants, where necessary for the conduct of 3jl1's business operations.

All third-party service providers who process personal data on behalf of 3jl1 are required to implement appropriate technical and organizational security measures and to process data only in accordance with our instructions.

6. Data Retention

3jl1 retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general rule:

• Account and identity data is retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for a period of three (3) years from the date of the interaction.
• Marketing consent records are retained for as long as you remain a registered player and for a reasonable period thereafter to demonstrate compliance.

Where personal data is no longer required for any lawful purpose, 3jl1 will securely delete or anonymize it in accordance with our internal data retention and disposal procedures.

7. Security Measures

3jl1 takes the security of your personal data seriously. We implement a range of technical and organizational measures designed to protect your information against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 3jl1 Platform
• Encryption of sensitive data at rest, including identity documents and financial information
• 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
• Multi-factor authentication requirements for administrative access to systems containing personal data
• Staff training on data protection obligations and information security best practices

8. Cookies and Similar Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 3jl1 Platform. They allow the Platform to recognize your device, maintain your session, and remember your preferences. 3jl1 also uses similar technologies such as web beacons and local storage objects.

8.2 Types of Cookies We Use

• Strictly necessary cookies: Required for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• 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 use the Platform, helping us identify areas for improvement.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our campaigns. These are only set with your consent.

8.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 3jl1 Platform, including your ability to log in or access certain features. Instructions for managing cookies are available in your browser's help documentation.

9. Your Data Protection Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 3jl1:

• Right to be informed: You have the right to be informed about how your personal data is collected and processed, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data 3jl1 holds about you, along with information about how it is being used.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update certain information directly through your account settings.
• 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 our legal 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 interests.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where processing is based on consent or contractual necessity.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• 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 protection rights have been violated.

To exercise any of these rights, please contact the 3jl1 Data Protection Officer using the contact details provided in Section 12 of this Policy. We will respond to all verified requests within thirty (30) days, in accordance with the requirements of the Data Privacy Act.

10. Children's Privacy

The 3jl1 Platform is strictly intended for individuals who are at least twenty-one (21) years of age. 3jl1 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on the 3jl1 Platform or provided us with personal data, please contact our support team immediately so that we can take appropriate action.

11. Changes to This Privacy Policy

3jl1 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, we will update the "Last Updated" date at the top of this page. For significant changes, we may also notify registered players via email or in-platform notification.

Your continued use of the 3jl1 Platform following the publication of any revised Privacy Policy constitutes your acknowledgment of the changes. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

12. Contact and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 3jl1, please contact our Data Protection Officer (DPO):

3jl1 Data Protection Officer
Email: [email protected]
General Support: [email protected]

Email addresses above are displayed as plain text for informational purposes. Please copy the address manually into your email client — they are not clickable links.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data protection rights have not been adequately addressed by 3jl1.