Privacy Policy

1 Overview

This Privacy Policy ("Policy") applies to all personal data collected, processed, and stored by 39JL ("39JL," "we," "us," or "our") in connection with your use of the 39JL online gaming platform, accessible at 39jl.app and through the 39JL mobile application (collectively, the "Platform").

By registering an account, accessing the Platform, or otherwise providing your personal information to 39JL, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy.

39JL is committed to transparency. We will only collect the personal data we genuinely need, use it only for the purposes described in this Policy, and protect it with appropriate technical and organisational security measures at all times.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, 39JL acts as the personal information controller in respect of all personal data collected through the Platform. This means that 39JL determines the purposes and means of processing your personal data.

Where 39JL engages third-party service providers to process personal data on its behalf — such as payment processors or identity verification providers — those parties act as personal information processors and are bound by data processing agreements that require them to handle your data in accordance with this Policy and applicable Philippine law.

3 Personal Data We Collect

39JL collects the following categories of personal data from players and Platform users:

39JL does not collect sensitive personal information — such as racial or ethnic origin, political opinions, religious beliefs, or health data — unless specifically required by law or with your explicit consent.

4 How We Collect Your Data

39JL collects your personal data through the following means:

• Direct registration: Information you provide when creating your 39JL account, including your name, email address, date of birth, and contact details;
• Identity verification: Documents and information submitted during KYC verification, including government-issued IDs such as a Philippine passport, SSS card, UMID, or driver's licence;
• Payment transactions: Financial details collected when you make deposits or request withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, or other supported payment methods;
• Platform usage: Data generated automatically as you navigate and interact with the 39JL Platform, including game activity, session data, and device information;
• Customer support: Information you provide when contacting the 39JL support team via chat, email, or any other communication channel;
• Cookies and tracking technologies: Data collected through cookies, web beacons, and similar technologies as described in Section 10 of this Policy;
• Third-party sources: In limited circumstances, 39JL may receive data about you from third-party identity verification providers or fraud prevention services to supplement the information you have provided directly.

5 Purpose of Processing

39JL processes your personal data for the following purposes:

• To create, manage, and maintain your 39JL player account;
• To verify your identity and age in compliance with KYC and AML obligations, including confirming that you are at least 21 years of age;
• To process deposits, withdrawals, and other financial transactions on the Platform;
• To provide, operate, and improve the 39JL gaming Platform and its features;
• To detect, investigate, and prevent fraud, money laundering, cheating, and other prohibited conduct;
• To comply with applicable Philippine laws and regulatory requirements, including reporting obligations to relevant authorities;
• To communicate with you about your account, transactions, promotions, and Platform updates;
• To provide customer support and resolve disputes;
• To enforce our Terms & Conditions and other applicable policies;
• To conduct responsible gaming monitoring and provide player protection tools in accordance with our Responsible Gaming Policy;
• To analyse Platform usage and improve user experience through aggregated, anonymised analytics.

6 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 39JL processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and 39JL — including account management, payment processing, and game provision;
• Legal obligation: Processing necessary to comply with applicable Philippine laws, including AML regulations, KYC requirements, and regulatory reporting obligations;
• Legitimate interests: Processing carried out for 39JL's legitimate business interests, such as fraud prevention, platform security, and service improvement, where those interests are not overridden by your rights and freedoms;
• Consent: Where 39JL relies on your consent as the legal basis for processing — such as for marketing communications — you have the right to withdraw that consent at any time by contacting our support team.

7 Sharing Your Personal Data

39JL 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 only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions;
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and age;
• Fraud prevention services: Providers of fraud detection and prevention tools used to protect the integrity of the 39JL Platform;
• Technology and hosting providers: Cloud hosting, data storage, and IT infrastructure providers who process data on 39JL's behalf under strict data processing agreements;
• Regulatory and law enforcement authorities: Government agencies, regulators, and law enforcement bodies in the Philippines where disclosure is required by law, court order, or regulatory instruction;
• Professional advisers: Legal, accounting, and compliance advisers bound by professional confidentiality obligations.

All third-party processors engaged by 39JL are required to implement appropriate technical and organisational security measures and to process personal data only in accordance with 39JL's documented instructions.

8 Data Retention

39JL retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with 39JL's data disposal procedures. Where data is anonymised, it may be retained indefinitely for analytical purposes as it can no longer be linked to any individual.

9 Data Security

39JL 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:

• SSL/TLS encryption for all data transmitted between your device and the 39JL Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Secure, hashed storage of account passwords — 39JL staff cannot view your password in plain text;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular security assessments, vulnerability scanning, and penetration testing of the Platform;
• Multi-factor authentication options for player accounts;
• Continuous monitoring for suspicious activity, unauthorised access attempts, and data breaches.

10 Cookies & Tracking Technologies

39JL uses cookies and similar tracking technologies to operate and improve the Platform, personalise your experience, and analyse usage patterns. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled;
• Functional cookies: Used to remember your preferences and settings, such as language and display options;
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the Platform, helping 39JL identify areas for improvement;
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 39JL Platform. 39JL does not use cookies to serve third-party advertising or to track your activity on other websites.

11 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 39JL:

• Right to be informed: The right to know what personal data 39JL holds about you and how it is being used — as set out in this Policy;
• Right of access: The right to request a copy of the personal data 39JL holds about you;
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to 39JL's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for specific purposes, including direct marketing;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact the 39JL support team. We will respond to all verified requests within thirty (30) days. In some cases, we may need to verify your identity before processing your request.

12 Minors & Age Policy

The 39JL Platform is strictly intended for individuals who are at least twenty-one (21) years of age. 39JL does not knowingly collect personal data from anyone under the age of 21. Age verification is conducted as part of the KYC process for all registered players.

If 39JL discovers or has reason to believe that personal data has been collected from a person under the age of 21, the relevant account will be immediately suspended, all associated data will be reviewed, and the data will be deleted to the extent permitted by law. Any deposits made by an underage player may be returned at 39JL's discretion after deducting applicable processing costs.

Parents and guardians who believe that a minor may have registered on the 39JL Platform are encouraged to contact our support team immediately so that the matter can be investigated and resolved promptly.

13 Cross-Border Data Transfers

In some cases, personal data collected by 39JL may be transferred to, stored in, or processed in countries outside the Philippines — for example, where 39JL's technology infrastructure or third-party service providers are located in other jurisdictions.

Where such transfers occur, 39JL ensures that appropriate safeguards are in place to protect your personal data in accordance with the requirements of the Philippine Data Privacy Act of 2012. These safeguards may include contractual data transfer agreements, standard contractual clauses, or transfers to jurisdictions that have been assessed as providing an adequate level of data protection.

By using the 39JL Platform and providing your personal data, you acknowledge and consent to the transfer of your data as described in this section, subject always to the protections described herein.

14 Amendments to This Policy

39JL reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform features. When material changes are made, we will notify registered players via the email address associated with their account and/or by displaying a prominent notice on the Platform.

The date of the most recent revision is displayed at the top of this page. Your continued use of the 39JL Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how 39JL protects your personal data.

15 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way 39JL handles your personal data, please contact our Data Privacy team. We take all privacy concerns seriously and aim to respond within twenty-four (24) hours.

If you are not satisfied with 39JL's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. Information about the NPC and how to file a complaint is available through official Philippine government channels.