396jl Privacy Policy

396jl operates as an online gaming platform serving Filipino players across the Philippines, offering JILI slots, live bingo, sports betting, sabong, and live dealer casino games. Operating within the PAGCOR regulatory framework and in compliance with Philippine data protection law, 396jl is committed to processing player data lawfully, fairly, and transparently.

This Policy applies to all personal data collected through the 396jl Platform — whether submitted directly by you during registration, collected automatically through your use of the site, or received from third-party service providers in connection with platform operations. It applies to all current and former registered players, as well as individuals who browse the 396jl website without registering an account.

This Policy should be read alongside the 396jl Terms & Conditions, which govern the legal relationship between you and 396jl as a Platform user.

For the purposes of the Data Privacy Act of 2012 and this Policy, 396jl is the personal information controller in respect of all data collected through the Platform. As personal information controller, 396jl determines the purposes and means by which your personal data is processed and bears primary responsibility for ensuring that processing complies with applicable Philippine data protection law.

Where 396jl engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, or cloud infrastructure providers — those parties act as personal information processors under the terms of written data processing agreements that bind them to handle your data only in accordance with 396jl's instructions and this Policy.

396jl collects personal data through several channels. The categories of data collected, together with the circumstances of collection, are described below:

396jl does not knowingly collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive data — such as government ID details — is collected, it is subject to heightened security controls and accessed only by authorized compliance and support personnel.

396jl processes personal data for the following specific, legitimate purposes:

• Account Management: To create, maintain, verify, and manage your 396jl Player Account, including authentication of login sessions and processing of account settings changes;
• Age and Identity Verification: To confirm that all players meet the mandatory 21-year minimum age requirement under PAGCOR regulations, and to verify player identity in compliance with KYC obligations;
• Payment Processing: To facilitate GCash and PayMaya deposits, bank transfers, withdrawal requests, and the maintenance of accurate wallet balances denominated in Philippine Peso;
• Regulatory and Legal Compliance: To comply with PAGCOR regulatory requirements, Philippine anti-money laundering laws (AMLA), and any lawful requests from authorized government bodies;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, account compromise, and abuse of the Platform's bonus and promotions systems;
• Platform Operation and Improvement: To analyze gameplay patterns, session data, and user behavior for the purpose of improving game selection, platform performance, and the overall 396jl user experience;
• Customer Support: To respond to and resolve queries, complaints, and disputes submitted through live chat, email, Messenger, or Viber;
• Marketing and Promotions: To send you information about 396jl bonuses, tournaments, new games, and promotions where you have provided consent or where we have a legitimate interest in contacting existing customers about relevant offers. You may withdraw marketing consent at any time via your account settings.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, 396jl processes personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and 396jl — including account management, payment processing, and game access — is carried out on the basis that it is necessary to fulfill our contractual obligations to you;
• Legal Obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, and other applicable Philippine laws is carried out on the basis of legal obligation;
• Legitimate Interests: Processing carried out for fraud prevention, platform security, and improvement of the Platform's services is based on 396jl's legitimate interests as an online gaming operator, balanced against your privacy rights;
• Consent: Processing for marketing communications and optional data collection (such as optional profile information) is carried out on the basis of your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

396jl does not sell, rent, or trade your personal data to third parties for their own commercial purposes. Data is shared with third parties only under the following circumstances and subject to appropriate contractual safeguards:

• Payment Service Providers: GCash (G-Xchange, Inc.), PayMaya (Voyager Innovations, Inc.), and Philippine banking partners receive transaction data necessary to facilitate deposits and withdrawals. These providers are subject to Bangko Sentral ng Pilipinas (BSP) regulation and their own privacy policies;
• Identity Verification Providers: Third-party KYC service providers receive identity document data as necessary to complete regulatory verification requirements. These providers are contractually bound to process data only for 396jl's stated verification purposes;
• Game Content Providers: Licensed game providers such as JILI may receive pseudonymous session and wagering data for game integrity monitoring and RTP certification purposes. No identifiable personal data is shared with game providers beyond what is strictly necessary;
• Regulatory Authorities: PAGCOR and other authorized Philippine government bodies may receive player data where required by law, court order, or regulatory directive. 396jl will notify affected players of such disclosures where legally permitted to do so;
• Technology and Infrastructure Providers: Cloud hosting, cybersecurity, and analytics providers who process data on 396jl's behalf under data processing agreements that require equivalent data protection standards;
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of 396jl's business, player data may be transferred as part of that transaction. Affected players will be notified in advance where possible.

396jl retains personal data only for as long as is necessary to fulfill the purposes described in this Policy, or as required by applicable Philippine law. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your active Player Account and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and AMLA obligations;
• Transaction and Financial Records: Retained for a minimum of ten (10) years in compliance with Philippine AMLA record-keeping requirements applicable to covered persons;
• Gaming Activity Logs: Retained for a minimum of three (3) years for regulatory compliance, responsible gaming monitoring, and dispute resolution purposes;
• Customer Support Records: Retained for three (3) years following resolution of the relevant inquiry or complaint;
• Marketing Consent Records: Retained for the duration of your opt-in status plus two (2) years following any withdrawal of consent, as evidence of prior consent.

At the expiry of the applicable retention period, personal data is securely deleted, anonymized, or pseudonymized in accordance with 396jl's data disposal procedures.

396jl implements technical and organizational security measures appropriate to the nature and sensitivity of the personal data processed. Key security controls include:

• Encryption in Transit: All data transmitted between your browser and the 396jl Platform is protected using Transport Layer Security (TLS) with 256-bit encryption — the same standard used by Philippine commercial banks for online banking portals;
• Encryption at Rest: Sensitive personal data stored in 396jl databases — including identity documents, payment references, and password hashes — is encrypted at rest using industry-standard encryption algorithms;
• Access Controls: Access to personal data is restricted to 396jl staff and authorized third-party processors on a strict need-to-know basis. Role-based access controls and audit logging are in place for all systems holding personal data;
• Two-Factor Authentication: 396jl enforces two-factor authentication via SMS OTP for player account access, reducing the risk of unauthorized account access through compromised credentials;
• Intrusion Detection and Monitoring: The 396jl platform infrastructure is continuously monitored for anomalous activity, unauthorized access attempts, and potential security incidents;
• Data Breach Response: In the event of a personal data breach that poses a risk to player rights, 396jl will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach and will notify affected individuals without undue delay.

The 396jl Platform uses cookies and similar tracking technologies to operate correctly and improve your experience. The categories of cookies used are as follows:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They maintain your login session, remember your language preference, and enable basic security features. These cookies cannot be disabled without affecting core Platform functionality;
• Performance and Analytics Cookies: These cookies collect anonymized information about how players use the Platform — such as which pages are visited most frequently, how long sessions last, and which games are most popular. This data is used solely to improve the 396jl Platform and is not linked to individual identities;
• Functionality Cookies: These cookies remember your Platform preferences — such as game display settings and responsible gaming preferences — to personalize your experience across sessions.

396jl does not use third-party advertising or retargeting cookies that track your activity across other websites. Where any non-essential cookies are used, your consent is obtained before they are placed. You may manage cookie preferences through your browser settings at any time; however, disabling strictly necessary cookies may impair your ability to use the Platform.

As a data subject under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by 396jl:

• Right to Be Informed: You have the right to be informed of how your personal data is collected, processed, and protected — as described in this Policy;
• Right of Access: You may request a copy of the personal data 396jl holds about you, together with information about how it is being processed;
• Right to Rectification: You may request the correction of any inaccurate or incomplete personal data held by 396jl. Account details can be updated directly within your account settings for most data fields;
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 396jl's legal retention obligations under PAGCOR and AMLA requirements;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to 396jl demonstrating compelling grounds for continued processing;
• Right to Data Portability: You may request a copy of the personal data you have provided to 396jl in a structured, commonly used, and machine-readable format;
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that 396jl has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of these rights, please contact 396jl at [email protected] with the subject line "Data Privacy Request — [Right Type]." We will respond to valid requests within fifteen (15) calendar days of receipt.

If 396jl becomes aware that personal data has been collected from a person under the age of 21, that data will be deleted and the associated account permanently closed without notice. Account balances associated with verified underage accounts will be subject to regulatory review prior to any refund determination.

If you are a parent or guardian and believe that a person under your care has created a 396jl account or submitted personal information to the Platform, please contact 396jl support immediately at [email protected].

In the course of operating the 396jl Platform, personal data may be transferred to, stored, or processed in countries outside the Philippines — for example, where cloud infrastructure providers or game content providers maintain data centers or processing facilities in other jurisdictions.

Where such transfers occur, 396jl ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required by the Data Privacy Act of 2012. Safeguards include contractual data processing agreements incorporating the standard data protection clauses recognized by the National Privacy Commission, and transfers to jurisdictions with an adequate level of data protection as determined by applicable Philippine law.

By using the 396jl Platform and submitting your personal data, you acknowledge that your information may be transferred to and processed in jurisdictions other than the Philippines, in accordance with the safeguards described above.

396jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or Platform operations. Where material changes are made that significantly affect your rights, 396jl will notify registered players via SMS to their registered mobile number or via a prominent notice on the Platform at least 7 days before the changes take effect.

The "Effective Date" at the top of this Policy reflects the date on which the most recent version became operative. Minor amendments — including clarifications, corrections, and editorial improvements that do not materially alter the substance of the Policy — may be made without advance notice.

Continued use of the 396jl Platform following the effective date of any amended Policy constitutes acceptance of the revised terms. If you do not agree with the amended Policy, you should cease using the Platform and may close your account in accordance with the Terms & Conditions.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 396jl, please contact the Data Protection Officer through the following channels:

• Email: [email protected] — subject line: "DPO — Data Privacy Inquiry";
• Live Chat: Available 24 hours a day, 7 days a week via the 396jl Platform;
• Messenger & Viber: Available during daytime hours for general privacy queries.

Formal data subject rights requests must be submitted by the registered account holder and may require identity verification before they can be processed.

If you are not satisfied with 396jl's response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the regulatory body responsible for enforcing the Data Privacy Act of 2012.