Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 366jl Gaming Corporation ("366jl", "we", "us", or "our"), a duly registered gaming operator licensed by the Philippine Amusement and Gaming Corporation (PAGCOR), collects, uses, stores, protects, and discloses personal information of users ("you", "your", or "user") of the 366jl online gaming platform ("Platform").

366jl is committed to protecting your privacy and ensuring the security of your personal information in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and all relevant issuances of the National Privacy Commission ("NPC").

This Policy applies to all personal information collected through the Platform, including our website, mobile applications, customer support channels, and any other services we provide. By accessing or using the Platform, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Policy.

2. Information We Collect

366jl collects various types of personal information to provide, maintain, protect, and improve our services, comply with legal and regulatory obligations, and communicate with you effectively.

2.1 Information You Provide Directly

When you register for an account, use our services, or communicate with us, you voluntarily provide the following information:

• Account Registration Information: Full legal name, date of birth, gender, email address, mobile phone number, physical address, username, password, and security questions.
• Identity Verification Documents: Government-issued identification such as Philippine passport, driver's license, Unified Multi-Purpose ID, PhilHealth ID, or other valid identification documents, including photographs and identification numbers.
• Financial Information: Payment method details including GCash account information, Maya (PayMaya) account details, bank account numbers and names, cryptocurrency wallet addresses, and transaction history.
• Communication Records: Content of your communications with our customer support team, including chat transcripts, emails, phone call recordings, and support tickets.
• Marketing Preferences: Your preferences regarding promotional communications, newsletters, and marketing materials.
• Responsible Gaming Information: Self-imposed deposit limits, session time limits, cooling-off period requests, and self-exclusion preferences.

2.2 Information Collected Automatically

When you access and use the 366jl Platform, we automatically collect certain information through cookies, web beacons, and similar technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), and mobile network information.
• Usage Information: Pages visited, games played, bet amounts and frequencies, time spent on the Platform, click patterns, navigation paths, and features accessed.
• Technical Information: IP address, geolocation data (country, region, city), internet service provider, referral URLs, and date/time stamps of access.
• Gaming Activity: Betting history, win/loss records, bonus usage, tournament participation, and gameplay patterns.

2.3 Information from Third Parties

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

• Payment processors (GCash, Maya, banks) verifying transaction details and account ownership
• Identity verification services confirming the authenticity of submitted documents
• Fraud prevention agencies providing information about suspicious activities
• Affiliate partners and marketing platforms regarding referrals and campaigns
• Game providers supplying gameplay data and technical performance metrics

3. How We Use Your Information

366jl uses the personal information we collect for the following purposes, all of which are essential to providing you with secure, compliant, and high-quality gaming services:

3.1 Service Provision and Account Management

• Creating, maintaining, and managing your 366jl account
• Processing deposits, withdrawals, and other financial transactions
• Providing access to games, betting markets, and platform features
• Recording and tracking your gaming activity and transaction history
• Calculating and crediting bonuses, promotions, and loyalty rewards
• Facilitating customer support and resolving disputes

3.2 Legal and Regulatory Compliance

• Verifying your identity and age to ensure compliance with 21+ age restrictions
• Complying with PAGCOR licensing requirements and gaming regulations
• Meeting anti-money laundering (AML) and counter-terrorism financing (CTF) obligations
• Fulfilling tax reporting and financial record-keeping requirements
• Responding to legal requests, court orders, and regulatory inquiries
• Investigating and preventing fraud, cheating, and other prohibited activities

3.3 Security and Fraud Prevention

• Detecting and preventing unauthorized account access
• Identifying suspicious betting patterns and collusion attempts
• Protecting against fraudulent transactions and payment disputes
• Monitoring for bot usage, automated betting systems, and other violations
• Enforcing Terms and Conditions and platform policies
• Maintaining the integrity and fairness of games

3.4 Service Improvement and Personalization

• Analyzing usage patterns to improve platform functionality and user experience
• Personalizing game recommendations based on your preferences
• Optimizing website and mobile app performance
• Conducting research and developing new features and services
• Testing and troubleshooting technical issues

3.5 Marketing and Communications

• Sending promotional offers, bonuses, and special event notifications (with your consent)
• Providing updates about platform features, games, and services
• Distributing newsletters and personalized marketing content
• Conducting customer satisfaction surveys and feedback requests
• Informing you about responsible gaming resources and tools

4. Information Sharing and Disclosure

366jl respects your privacy and does not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your information only in the following limited circumstances:

4.1 Service Providers and Business Partners

We share information with trusted third-party service providers who perform services on our behalf, including:

• Payment Processors: GCash, Maya, banks, and cryptocurrency platforms to process deposits and withdrawals
• Identity Verification Services: Third-party vendors who verify the authenticity of identification documents
• Game Providers: Software suppliers such as Pragmatic Play, Evolution Gaming, and others who deliver gaming content
• Cloud Hosting Providers: Data storage and server infrastructure providers
• Customer Support Tools: Live chat platforms, ticketing systems, and CRM software providers
• Marketing Platforms: Email service providers and analytics tools (with your consent)

All service providers are contractually obligated to maintain the confidentiality and security of your information and are prohibited from using it for any purpose other than providing services to 366jl.

4.2 Legal and Regulatory Authorities

We may disclose your information to government agencies, regulators, and law enforcement when required by law or when we believe disclosure is necessary to:

• Comply with PAGCOR regulations, gaming laws, and AML/CTF requirements
• Respond to valid legal processes such as subpoenas, court orders, or warrants
• Cooperate with law enforcement investigations
• Report suspicious activities to the Anti-Money Laundering Council (AMLC)
• Fulfill tax reporting obligations with the Bureau of Internal Revenue (BIR)

4.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity. You will be notified via email and/or prominent notice on our Platform of any such change in ownership or control of your personal information.

4.4 With Your Consent

We may share your information with third parties when you have provided explicit consent to do so, such as when you participate in co-branded promotions or authorize social media integrations.

4.5 Aggregated and De-identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you for research, analytics, or business purposes without restriction.

5. Data Security Measures

366jl implements comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction.

5.1 Technical Safeguards

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS technology. Sensitive data stored in our databases is encrypted at rest.
• Firewalls: Enterprise-grade firewalls protect our network infrastructure from unauthorized access and cyberattacks.
• Intrusion Detection: Real-time monitoring systems detect and respond to suspicious activities and potential security breaches.
• Secure Authentication: Password hashing using industry-standard algorithms and optional two-factor authentication (2FA) for enhanced account security.
• Regular Security Audits: Third-party penetration testing and vulnerability assessments conducted quarterly.

5.2 Administrative Safeguards

• Access to personal information is restricted to authorized personnel only, based on the principle of least privilege
• All employees and contractors undergo background checks and sign confidentiality agreements
• Comprehensive data protection training for all staff handling personal information
• Incident response plan and data breach notification procedures in compliance with NPC requirements
• Regular reviews and updates of security policies and procedures

5.3 Physical Safeguards

• Secure data centers with 24/7 monitoring, access controls, and environmental protection
• Biometric and badge-based access control systems for restricted areas
• Video surveillance of critical infrastructure
• Secure disposal procedures for physical documents containing personal information

6. Cookies and Tracking Technologies

366jl uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content.

6.1 Types of Cookies We Use

• Essential Cookies: Required for platform functionality, including session management, security, and authentication. These cannot be disabled.
• Performance Cookies: Collect anonymous data about how visitors use the Platform to help us improve performance and user experience.
• Functional Cookies: Remember your preferences, settings, and login information to provide a personalized experience.
• Marketing Cookies: Track your browsing activity to deliver relevant advertisements and measure campaign effectiveness (used only with your consent).

6.2 Managing Cookie Preferences

Most web browsers allow you to control cookies through their settings. You can configure your browser to refuse all cookies, accept only certain cookies, or notify you when a cookie is being set. However, disabling essential cookies may prevent you from using certain Platform features.

To manage cookies, access your browser settings or visit the privacy settings section of your 366jl account.

6.3 Third-Party Tracking

We work with third-party analytics providers (such as Google Analytics) and advertising networks that may use cookies and similar technologies to collect information about your online activities across different websites and services. These third parties are subject to their own privacy policies.

7. Your Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request access to your personal information held by 366jl. You can view most of your information directly through your account dashboard. For additional information, contact our Data Protection Officer.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most information through your account settings or by contacting customer support.

7.3 Right to Erasure

You have the right to request deletion of your personal information, subject to legal retention requirements. Note that we must retain certain information for regulatory compliance (such as transaction records for AML purposes) even after account closure.

7.4 Right to Restrict Processing

You have the right to request limitation on how we process your personal information in certain circumstances, such as when you contest the accuracy of the information or object to processing.

7.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another data controller.

7.6 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes or when processing is based on legitimate interests. You can opt out of marketing communications through your account settings.

7.7 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

7.8 Right to File a Complaint

You have the right to file a complaint with the National Privacy Commission if you believe your privacy rights have been violated. Contact details: National Privacy Commission, 5th Floor, Philippine International Convention Center, Vicente Sotto St., Pasay City, or email [email protected].

8. Data Retention and Deletion

366jl retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

8.1 Active Account Data

While your account is active, we retain all information necessary to provide services, maintain security, and comply with ongoing regulatory requirements.

8.2 Closed Account Data

After account closure, we retain certain information to comply with legal retention obligations:

• Transaction records and financial data: Minimum 5 years (as required by AML/CTF laws and tax regulations)
• Identity verification documents: Minimum 5 years (PAGCOR and AML requirements)
• Gaming activity logs: Minimum 5 years (gaming regulations)
• Customer communications: Minimum 2 years (dispute resolution purposes)

8.3 Deletion Process

After the applicable retention period expires, personal information is securely deleted or anonymized. Deletion is performed using industry-standard methods to ensure information cannot be recovered or reconstructed.

9. International Data Transfers

366jl primarily stores and processes your personal information within the Philippines. However, some of our service providers may process data in other countries. When we transfer personal information outside the Philippines, we ensure appropriate safeguards are in place to protect your information, including:

• Contractual obligations requiring service providers to maintain Philippine data protection standards
• Verification that the recipient country has adequate data protection laws
• Use of standard contractual clauses approved by the National Privacy Commission
• Encryption and security measures during data transmission

10. Children's Privacy

The 366jl Platform is strictly intended for individuals aged 21 years or older. We do not knowingly collect personal information from individuals under 21 years of age. If we discover that we have inadvertently collected information from a minor, we will immediately delete such information and close the associated account.

Parents and guardians are responsible for monitoring their children's internet activities and ensuring minors do not access gaming platforms. If you believe a minor has provided personal information to 366jl, please contact us immediately at [email protected].

11. Changes to This Policy

366jl reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last Updated" date at the top of this Policy
• Notify you via email to your registered email address
• Display a prominent notice on the Platform homepage
• Require your acknowledgment upon next login for significant changes

Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your information.

12. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us: