jl39 Privacy Policy

Data Processing at a Glance

The table below provides a plain-language summary of how jl39 handles personal data. The detailed sections that follow provide the full legal basis and context for each item.

1 About This Policy

This Privacy Policy applies to all personal information collected, stored, used, and disclosed by jl39 (referred to as "jl39," "we," "us," or "our") in connection with the online gaming platform operated at jl39.club and all associated services, games, customer support channels, and communication tools accessible through or in connection with that platform.

This policy applies to all registered players, visitors to the jl39 website, and individuals who interact with jl39 through customer support or promotional channels. It applies regardless of where you are physically located in the Philippines — whether you're in Metro Manila, Cebu, Davao, Iloilo, Cagayan de Oro, or any other part of the archipelago.

This Privacy Policy should be read together with jl39's Terms & Conditions, which govern your overall use of the platform. By registering an account or using jl39's services, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein, to the extent that consent is the applicable legal basis for such processing.

jl39 designates a Data Protection Officer (DPO) who is responsible for overseeing compliance with this policy and with the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations. Contact details for the DPO are provided in Section 16 of this policy.

2 Personal Data We Collect

jl39 collects the following categories of personal data, depending on your interaction with the platform:

Identity and Contact Information

• Full legal name as it appears on your government-issued identification;
• Date of birth (for age verification purposes — you must be 21 or older);
• Philippine mobile phone number in +63 format;
• Email address;
• Residential address (required for KYC verification);
• Government-issued ID type and number (UMID, PhilSys ID, passport, driver's licence, etc.);
• Selfie photograph or facial image submitted for identity verification.

Financial and Payment Information

• GCash or Maya account details (mobile number associated with the e-wallet account);
• Bank account details for players using BPI, BDO, or Metrobank transfers;
• Deposit and withdrawal transaction records including amounts, dates, and reference numbers;
• Source of funds information provided in response to AML compliance requests.

Gaming and Account Activity

• Account login history including timestamps and IP addresses;
• Game participation records including games played, bet amounts, outcomes, and session durations;
• Bonus and promotional credit history;
• Responsible gaming tool settings and any self-exclusion or limit requests;
• Customer support interaction records including chat transcripts and email correspondence.

Technical and Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type and version;
• Cookie identifiers and similar tracking technology data (see Section 9);
• Session data and platform interaction logs collected for security and fraud prevention purposes.

3 How We Collect Your Data

jl39 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make deposits or withdrawals, contact support, set responsible gaming preferences, or otherwise interact with the jl39 platform;
• Automatically — through cookies, log files, pixel tags, and similar technologies when you browse or use the jl39 website (see Section 9 for details on cookies);
• From payment service providers — jl39 receives transaction confirmation data from GCash, Maya, and banking partners to verify and process payments;
• From identity verification providers — jl39 may use third-party KYC service providers to assist with document verification and identity checks, who may return verification results and data quality flags;
• From fraud and security monitoring services — technical risk signals from third-party fraud detection services to help identify suspicious account activity.

4 Why We Use Your Personal Data

jl39 uses your personal data for the following specific purposes:

• Account creation and management — to register your account, verify your identity, maintain accurate account records, and provide access to jl39 services;
• Age and eligibility verification — to confirm that you meet the minimum age requirement of 21 years old and are legally permitted to use online gaming services;
• KYC and AML compliance — to fulfill our legal obligations under anti-money laundering regulations, including verifying the source of deposited funds and reporting suspicious activity to AMLC (Anti-Money Laundering Council) and other competent Philippine authorities as required by law;
• Payment processing — to process deposits and withdrawals via GCash, Maya, bank transfers, and other accepted payment methods, and to reconcile transaction records;
• Game provision and account operation — to deliver the gaming services you use, record game outcomes, credit winnings, apply bonuses, and maintain gaming history;
• Responsible gaming — to monitor gaming patterns for signs of problem gambling, implement deposit limits, loss limits, cooling-off periods, and self-exclusion requests, and to comply with responsible gaming obligations;
• Customer support — to respond to your inquiries, resolve disputes, process complaints, and maintain records of support interactions;
• Security and fraud prevention — to detect and prevent fraudulent account activity, unauthorized access, multi-accounting, money laundering, and other prohibited conduct;
• Marketing and promotions — to send promotional communications, bonus offers, and product updates to players who have opted in to receive such communications (see Section 13);
• Platform improvement — to analyze aggregated usage patterns, identify technical issues, test new features, and improve the overall performance of the jl39 platform.

5 Legal Bases for Processing

Under the Data Privacy Act of 2012 (RA 10173), jl39 processes personal data on the following legal bases:

• Performance of a contract — processing necessary to provide you with jl39's gaming services, process your deposits and withdrawals, and manage your account as described in the Terms & Conditions;
• Compliance with a legal obligation — processing required by applicable Philippine laws including KYC requirements, AML obligations under RA 9160 (Anti-Money Laundering Act) as amended, PAGCOR regulatory requirements, and tax reporting obligations;
• Legitimate interests — processing necessary for jl39's legitimate business interests in fraud prevention, security monitoring, platform improvement, and responsible gaming oversight, where those interests are not overridden by your rights and freedoms;
• Consent — processing for marketing and promotional communications, where you have given explicit, informed, and freely given consent. You may withdraw your marketing consent at any time without affecting the lawfulness of processing based on other legal grounds.

6 Sharing Your Personal Data

jl39 does not sell your personal data to third parties. We do not share your personal information for commercial purposes unrelated to the provision of our services. We may share your data with the following categories of third parties for the specific purposes described:

• Payment service providers — GCash (G-Xchange, Inc.), Maya (Voyager Innovations), and Philippine banking institutions, solely for the purpose of processing your deposits and withdrawals;
• Identity verification and KYC providers — third-party service providers engaged to assist with documentary identity verification, facial recognition matching, and AML screening;
• Gaming software providers — providers of the game software and live dealer platforms used on jl39, who may receive game participation data necessary for game operation;
• IT and hosting service providers — cloud hosting and infrastructure providers who process data on jl39's behalf under contractual data processing agreements;
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government bodies, where jl39 is legally required to disclose information;
• Professional advisors — lawyers, accountants, and auditors acting in a professional advisory capacity, subject to strict confidentiality obligations.

All third-party service providers who process personal data on jl39's behalf are bound by contractual data processing agreements that require them to process data only for the specified purpose, implement appropriate security measures, and comply with applicable Philippine data protection law.

7 International Data Transfers

Some of jl39's third-party service providers — including cloud hosting infrastructure, gaming software platforms, and KYC technology providers — may be located outside of the Philippines. Where personal data is transferred to recipients in countries not recognized by the National Privacy Commission as providing an adequate level of data protection, jl39 implements appropriate safeguards including contractual clauses that impose data protection obligations equivalent to those required under RA 10173.

By using jl39's services, you acknowledge that your personal data may be transferred to, stored in, and processed in countries outside of the Philippines, subject to the safeguards described above. jl39 will not transfer personal data internationally unless a lawful basis and appropriate protection mechanism is in place.

8 Data Retention

jl39 retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law, whichever is longer. The following general retention periods apply:

• Account and KYC records — retained for a minimum of five (5) years after account closure, as required by AML regulations and PAGCOR compliance obligations;
• Financial transaction records — retained for a minimum of five (5) years from the date of each transaction, in compliance with RA 9160 and its amendments;
• Gaming history — retained for a minimum of three (3) years from the date of each gaming session, or five (5) years if subject to a dispute or regulatory inquiry;
• Customer support records — retained for three (3) years from the date of resolution of each support interaction;
• Marketing consent records — retained until consent is withdrawn, plus a reasonable period thereafter to demonstrate compliance;
• Security and fraud logs — retained for up to two (2) years unless required for longer in connection with an ongoing investigation.

After the applicable retention period expires, personal data is securely deleted or anonymized in a manner that prevents re-identification. Data subject to an active legal hold, regulatory inquiry, or unresolved dispute will be retained until the matter is resolved, regardless of the standard retention period.

9 Cookies & Tracking Technologies

jl39 uses the following categories of cookies on the jl39.club website:

• Strictly Necessary Cookies — required for the platform to function. These include session management cookies that keep you logged in during your visit and security tokens that protect against cross-site request forgery. These cookies cannot be disabled without breaking core platform functionality;
• Functional Cookies — remember your preferences such as language settings, display options, and responsible gaming tool configurations to improve your experience across sessions;
• Analytics Cookies — used to understand how players use the jl39 platform at an aggregate level, identify technical issues, and improve performance. These cookies collect anonymized or pseudonymized data. Used only with your consent;
• Marketing and Promotional Cookies — used to deliver relevant promotional communications and measure the effectiveness of jl39's marketing activities. Used only with your explicit consent.

You may manage your cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies. Note that blocking strictly necessary cookies will prevent you from using the jl39 platform. Your cookie preferences for non-essential cookies can also be updated through the jl39 platform settings at any time.

10 Security Measures

jl39 implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Key measures include:

• SSL/TLS encryption applied to all data transmitted between your device and the jl39 platform, including account credentials, payment data, and KYC document uploads;
• Encryption at rest for sensitive personal data including KYC documentation and financial records stored in jl39's systems;
• Access controls limiting internal access to personal data to jl39 staff whose role requires it, with access logs maintained;
• Two-factor authentication available for all player accounts to protect against unauthorized login;
• Fraud monitoring systems that analyze account and transaction patterns to detect and respond to suspicious activity in real time;
• Regular security assessments of jl39's platform infrastructure, including vulnerability scanning and penetration testing.

While jl39 takes these measures seriously, no data transmission over the internet or electronic storage system can be guaranteed as completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, jl39 will notify the National Privacy Commission and, where required, affected individuals in accordance with Section 14 of this policy.

11 Your Rights Under RA 10173

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl39. To exercise any of these rights, contact jl39's Data Protection Officer at the details provided in Section 16:

jl39 will respond to data subject requests within thirty (30) days of receipt. Where a request is complex or involves a large volume of data, jl39 may extend this period by a further two months, notifying you of the extension within the initial thirty-day period. jl39 will not charge a fee for responding to data subject requests unless a request is manifestly unfounded or excessive.

If you are not satisfied with jl39's response to a data subject request or believe your rights under RA 10173 have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

12 Children's Privacy and Age Restriction

jl39 does not knowingly collect, store, or process personal data from any individual who is under 21 years of age. The minimum age requirement for registering and using jl39 is 21 years, consistent with PAGCOR's Philippine online gaming regulations.

If jl39 discovers or reasonably suspects that a registered account is held by an individual under the age of 21, it will immediately suspend the account, retain data only to the extent required for the investigation and any regulatory reporting obligation, and delete all other personal data associated with that account. Any balance held in an underage account will be handled in accordance with applicable regulatory guidance.

If you believe that jl39 has inadvertently collected personal data from a person under 21, please contact the DPO immediately at [email protected].

13 Marketing Communications

jl39 sends promotional communications — including bonus offers, new game announcements, and platform updates — only to players who have explicitly opted in to receive such communications during registration or through their account settings.

You may opt out of marketing communications at any time by: (a) clicking the unsubscribe link included in every marketing email; (b) updating your communication preferences in your jl39 account settings; or (c) contacting jl39 support at [email protected] and requesting to be removed from marketing communications.

Opting out of marketing communications will not affect your receipt of transactional messages, which are necessary for the operation of your account. Transactional messages include deposit confirmations, withdrawal notifications, KYC status updates, security alerts, and responses to support inquiries. These messages are sent regardless of marketing preference.

14 Data Breach Notification

In the event of a personal data breach — meaning any unauthorized access, disclosure, alteration, loss, or destruction of personal data held by jl39 — jl39 will:

• Conduct an immediate internal investigation to determine the nature, scope, and likely consequences of the breach;
• Notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, where it is likely to result in a risk to the rights and freedoms of affected individuals, in accordance with RA 10173 and NPC Circular 16-03;
• Notify affected data subjects without undue delay where the breach is likely to result in a high risk to their rights and freedoms, including where financial data or identity information may have been compromised;
• Notification to affected players will be delivered via the email address registered on their jl39 account and will include: a description of the nature of the breach, the categories of data involved, the likely consequences, the measures jl39 has taken or proposes to take, and a contact point for further information.

Where it is not immediately feasible to notify all affected individuals simultaneously, jl39 may issue a public notice on the jl39 platform as an interim measure.

15 Changes to This Privacy Policy

jl39 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform services. The effective date at the top of this page will be updated to reflect the date of the most recent revision.

Material changes to this Privacy Policy — meaning changes that significantly affect how we process your personal data or your rights as a data subject — will be communicated to registered players via email to their registered address at least seven (7) days before the changes take effect. Non-material amendments (such as formatting corrections or clarifications that do not change the substance of the policy) may be made without prior notice.

Your continued use of the jl39 platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the revised policy. We recommend reviewing this page periodically to stay informed of any changes.

16 Contact & Data Protection Officer

jl39 has designated a Data Protection Officer (DPO) responsible for overseeing data privacy compliance. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact:

• Data Protection Officer, jl39
• Email: [email protected] — please use subject line "Data Privacy Request" for all DPO correspondence
• Response time: jl39 targets acknowledgment of all DPO communications within 48 hours during Philippine business days, and full response within 30 calendar days

If you are not satisfied with jl39's handling of your personal data or a data subject request, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC accepts complaints from Philippine data subjects regarding the processing of their personal data by organizations subject to RA 10173.