35jl Privacy Policy

1. Introduction

35jl ("35jl", "we", "us", "our") is committed to protecting the privacy and personal data of all individuals who use the 35jl online gaming platform (the "Platform"). This Privacy Policy ("Policy") describes how 35jl collects, uses, stores, shares, and protects personal data 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) and its Implementing Rules and Regulations, as well as applicable guidelines issued by the National Privacy Commission (NPC) of the Philippines. Where relevant, this Policy also reflects the requirements of PAGCOR's data governance standards for licensed online gaming operators.

By registering an account on 35jl, accessing the Platform, or otherwise providing your personal data to us, you consent to the collection and processing of your personal data as described in this Policy. If you do not agree with this Policy, please do not use the 35jl Platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, 35jl is the Personal Information Controller in respect of the personal data you provide when using the Platform. This means that 35jl determines the purposes and means of processing your personal data.

If you have any questions, concerns, or requests relating to your personal data, please contact our Data Protection Officer (DPO) using the contact details above.

3. Data We Collect

3.1 Data You Provide Directly

When you register an account or interact with 35jl, we collect the following categories of personal data:

3.2 Data Collected Automatically

When you access the 35jl Platform, we automatically collect certain technical and behavioural data, including:

• IP address and approximate geographic location (city/region level);
• Device type, operating system, and browser version;
• Pages visited, features used, and time spent on the Platform;
• Game session data, including wagers placed, game outcomes, and session duration;
• Login timestamps and access logs;
• Referral source (how you arrived at the 35jl Platform).

3.3 Data from Third Parties

In certain circumstances, 35jl may receive personal data about you from third parties, including payment processors (for transaction verification), identity verification service providers (for KYC compliance), and fraud prevention agencies. We handle all such data in accordance with this Policy.

4. How We Use Your Data

35jl uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your 35jl account, including verifying your identity and age (21+) as required by PAGCOR regulations;
• Service Delivery: To provide you with access to games, process deposits and withdrawals, and deliver customer support;
• Legal & Regulatory Compliance: To fulfil our obligations under the Data Privacy Act, PAGCOR licensing requirements, and anti-money laundering (AML) regulations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform;
• Responsible Gaming: To monitor gaming behaviour and apply responsible gaming tools such as deposit limits, session reminders, and self-exclusion where appropriate;
• Platform Improvement: To analyse usage patterns and improve the features, performance, and user experience of the 35jl Platform;
• Marketing Communications: To send you promotional offers, bonuses, and updates about 35jl — but only where you have given your explicit consent to receive such communications. You may withdraw this consent at any time.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 35jl processes your personal data on the following legal bases:

• Consent: Where you have given clear, informed consent to the processing of your data for a specific purpose (e.g., marketing communications);
• Contractual Necessity: Where processing is necessary to perform our contract with you — that is, to provide the 35jl gaming service you have registered for;
• Legal Obligation: Where processing is required to comply with applicable laws and regulations, including PAGCOR licensing conditions, AML obligations, and NPC guidelines;
• Legitimate Interests: Where processing is necessary for 35jl's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.

6. Sharing Your Data

6.1 Service Providers

35jl may share your personal data with carefully selected third-party service providers who assist us in operating the Platform. These include payment processors (GCash, Maya, banks), identity verification providers, cloud hosting providers, and customer support platform vendors. All service providers are contractually bound to process your data only on 35jl's instructions and in accordance with applicable data protection law.

6.2 Regulatory and Law Enforcement Authorities

35jl may disclose your personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities where required by law, court order, or regulatory directive. We will notify you of such disclosures where we are legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 35jl's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the privacy practices of the acquiring entity before your data is transferred.

7. Cookies & Tracking Technologies

35jl uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session, and gather analytics data. The types of cookies we use include:

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may affect the functionality of the 35jl Platform.

8. Data Retention

35jl retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulation. Specific retention periods include:

• Account and identity data: Retained for the duration of your account plus five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements;
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by AML regulations;
• Customer support communications: Retained for two (2) years from the date of the interaction;
• Marketing consent records: Retained for the duration of your consent plus three (3) years to demonstrate compliance;
• Technical and analytics data: Retained in anonymised or aggregated form for up to twenty-four (24) months.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, 35jl will securely delete or irreversibly anonymise the data.

9. Your Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 35jl:

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days.

10. Data Security

35jl implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the 35jl Platform is encrypted using TLS 1.2 or higher. Sensitive data at rest is encrypted using AES-256;
• Access Controls: Access to personal data is restricted to authorised 35jl personnel on a strict need-to-know basis. All staff with access to personal data undergo regular data privacy training;
• Two-Factor Authentication: 35jl supports and encourages the use of two-factor authentication (2FA) for all player accounts;
• Regular Security Audits: The Platform undergoes regular penetration testing and security audits by independent third-party specialists;
• Incident Response: 35jl maintains a documented data breach response procedure. In the event of a breach affecting your personal data, we will notify you and the NPC within the timeframes required by law.

11. Children's Privacy

The 35jl Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing online gambling in the Philippines. 35jl does not knowingly collect personal data from individuals under the age of 21.

If 35jl becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the 35jl Platform, please contact us immediately at [email protected].

12. Third-Party Links

The 35jl Platform may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to the 35jl Platform and does not cover the privacy practices of any third-party websites. 35jl is not responsible for the content or privacy practices of any linked third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Policy

35jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email and/or by posting a prominent notice on the Platform at least fourteen (14) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how 35jl protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 35jl handles your personal data, please reach out to our dedicated Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. For more information, visit the NPC's official channels.

For responsible gaming concerns, please visit our Responsible Gaming page.