366jl Casino – Privacy Policy

This Privacy Policy applies to all personal data collected, processed, stored, or transmitted by 366jl Casino ("366jl," "we," "us," "our") in connection with the operation of the online gaming platform accessible at https://366jl.co and any associated mobile web properties (collectively, the "Platform").

Data Controller: 366jl Casino is the data controller responsible for personal data collected through the Platform. As data controller, 366jl determines the purposes and means of processing your personal data and bears responsibility for ensuring that processing is conducted lawfully, fairly, and transparently in accordance with applicable Philippine law.

This Policy applies to all registered players, prospective players who browse the Platform without registering, and any individual who communicates with 366jl through support channels. By accessing the Platform or registering an account, you acknowledge that you have read and understood this Privacy Policy.

366jl collects the following categories of personal data in connection with the provision of its services. We limit collection to data that is necessary for the stated purpose.

We do not intentionally collect sensitive personal information as defined under the Data Privacy Act — including health information, sexual orientation, religious or political beliefs — in the ordinary course of platform operation. If such information is incidentally disclosed in support communications, it is handled with appropriate additional safeguards.

366jl collects personal data through the following channels and methods:

• Direct Provision: Information you provide directly during account registration, KYC verification submissions, payment setup, or when contacting our support team via live chat or email.
• Automated Collection: Technical data collected automatically when you access the Platform, including IP address, device identifiers, browser type, operating system, and session activity logs. This data is collected through standard server-side logging and, where applicable, cookies and similar tracking technologies.
• Payment Processors: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, and Visa/Mastercard payment gateways in connection with deposit and withdrawal processing. 366jl does not directly store full card numbers or e-wallet PINs.
• Third-Party Verification Services: Identity verification data returned by KYC service providers engaged to assist with document verification and fraud prevention processes.
• Gaming Platforms: Game session data generated by third-party game providers integrated into the 366jl platform, including wager amounts, game outcomes, and session durations.

366jl processes your personal data for the following specific, legitimate purposes:

1. Account Management: Creating and maintaining your 366jl player account, including processing registration, authenticating logins, and managing account settings.
2. Identity Verification (KYC): Verifying your identity and age in compliance with PAGCOR-aligned requirements and anti-money laundering obligations under Philippine law.
3. Payment Processing: Facilitating GCash, PayMaya, and bank deposits and withdrawals, reconciling transactions, and investigating payment disputes or discrepancies.
4. Platform Provision: Operating the gaming platform, delivering game services, recording game outcomes, applying bonus credits, and maintaining accurate betting records.
5. Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent transactions, unauthorized account access, bonus abuse, money laundering, and other prohibited conduct.
6. Regulatory Compliance: Meeting our legal obligations under the Data Privacy Act, PAGCOR regulations, Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
7. Customer Support: Responding to and resolving your support enquiries, account disputes, and payment issues.
8. Responsible Gaming: Administering self-exclusion, deposit limit, and cooling-off requests; monitoring account activity for indicators of problem gambling behavior where required by responsible gaming policy.
9. Service Improvement: Analyzing aggregated, anonymized platform usage data to improve game offerings, user experience, and operational efficiency.
10. Legal Claims: Establishing, exercising, or defending legal claims involving 366jl Casino.

Under the Data Privacy Act of 2012 and its Implementing Rules, 366jl relies on the following legal bases to process your personal data:

• Contractual Necessity: Processing necessary to perform our contract with you — including account operation, payment processing, and game delivery — is conducted on the basis that it is required to fulfill our contractual obligations under the Terms and Conditions.
• Legal Obligation: Processing required to comply with our legal obligations under Philippine law, including KYC verification, AMLA transaction reporting, and regulatory record-keeping, is conducted on the basis of legal obligation.
• Legitimate Interests: Processing for fraud prevention, security monitoring, platform improvement, and legal claims is conducted on the basis of our legitimate interests, balanced against your rights and interests as a data subject.
• Consent: Where we process data for optional purposes — such as promotional communications — we rely on your explicit, freely given consent, which you may withdraw at any time without penalty.

366jl does not sell your personal data. We share personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and Visa/Mastercard payment gateways receive transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are subject to Philippine BSP financial regulations.
• KYC & Identity Verification Providers: Third-party identity verification services receive copies of submitted identification documents and selfie verification images for the purpose of automated and manual document verification.
• Game Software Providers: Game providers integrated into the 366jl platform (including studios supplying slot, live dealer, and bingo software) receive session data necessary to deliver gameplay and verify game outcomes. These providers operate under gaming license terms that include data protection obligations.
• IT & Infrastructure Providers: Cloud hosting, database management, and platform infrastructure providers that process data on our behalf under data processing agreements that impose equivalent data protection standards.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies as required by applicable law, court order, or regulatory direction.
• Legal Advisers: Legal counsel and professional advisers engaged in connection with legal proceedings, compliance review, or regulatory matters, subject to professional confidentiality obligations.

All third-party recipients who process personal data on behalf of 366jl are required to handle such data only in accordance with our instructions and under data processing agreements that meet the requirements of the Data Privacy Act.

The 366jl platform uses cookies and similar technologies to maintain session integrity, improve platform performance, and detect fraudulent access patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without preventing access to core platform features.
• Functional Cookies: Store your preferences such as language settings, game lobby layout preferences, and responsible gaming tool settings to provide a more personalized experience.
• Analytical Cookies: Collect aggregated, anonymized data about how players use the Platform — such as which pages are visited most frequently — to help us improve platform performance and user experience.
• Security Cookies: Used for fraud detection and prevention, including device fingerprinting to identify anomalous login patterns that may indicate unauthorized account access.

Most modern browsers allow you to control cookie settings through your browser preferences. Disabling strictly necessary cookies will impair or prevent access to the 366jl platform. Disabling functional or analytical cookies will not prevent access but may reduce the quality of your experience.

366jl retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account Data & Gaming Records: Retained for the duration of your active account plus a minimum of five (5) years following account closure, as required by PAGCOR compliance and AMLA record-keeping obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA and BSP record-keeping requirements applicable to financial service providers.
• KYC Documents: Retained for the duration of the account relationship plus five (5) years following account closure, or longer if required by active regulatory or legal proceedings.
• Support Communications: Retained for two (2) years from the date of the interaction, or longer where the communication relates to an unresolved dispute or legal claim.
• Technical Logs: Access and security logs retained for a rolling period of twelve (12) months, unless specific logs are flagged in connection with security investigation or legal proceedings.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with industry-standard data disposal procedures. Where anonymization is performed, the resulting data is no longer personal data and may be retained indefinitely for aggregate analytics purposes.

366jl implements comprehensive technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security framework includes, but is not limited to:

• Encryption in Transit: All data transmitted between your device and the 366jl platform is encrypted using Transport Layer Security (TLS) 1.2 or higher, providing 256-bit encryption for all communications.
• Encryption at Rest: Sensitive data categories, including identity documents, payment details, and authentication credentials, are encrypted at rest using AES-256 encryption within our database infrastructure.
• Access Controls: Internal access to personal data is restricted to personnel with a legitimate operational need. Role-based access controls, multi-factor authentication, and audit logging are applied to all internal system access.
• Password Security: Player passwords are stored exclusively as salted cryptographic hashes. No 366jl employee or system can retrieve your plaintext password; password recovery requires OTP verification.
• Penetration Testing: The 366jl platform undergoes regular security assessments, including penetration testing and vulnerability scanning, conducted by qualified security professionals.
• Incident Response: 366jl maintains a data breach response procedure that includes rapid containment, impact assessment, and notification to the National Privacy Commission and affected data subjects in accordance with NPC Circular 16-03 requirements.

While 366jl employs rigorous security measures, no online system can guarantee absolute security. We encourage players to maintain strong, unique passwords for their accounts and to contact our support team immediately upon suspecting unauthorized account access.

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 366jl. These rights are meaningful and exercisable — not just theoretical:

To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Privacy Request – [Your Username]" and a description of the right you wish to exercise. Identity verification will be required before processing any data subject request. 366jl will respond within thirty (30) calendar days of receipt of a verified request.

If you believe that 366jl has not adequately addressed your data privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

The 366jl platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect personal data from individuals under the age of 21. This age restriction is consistent with PAGCOR regulations governing online casino gaming in the Philippines and is enforced through our identity verification procedures.

If we become aware that personal data of an individual under 21 has been collected — whether through registration using false age information or any other means — we will immediately suspend the relevant account, delete or quarantine the associated personal data, and initiate our underage gambling response procedure, which may include reporting to relevant authorities.

Parents or guardians who believe that a minor has registered on the 366jl platform are encouraged to contact our support team immediately at [email protected]. We treat reports of potential underage account activity as high-priority and will respond within 24 hours.

In the course of operating the 366jl platform, certain personal data may be processed by service providers located outside the Philippines — including game software providers, cloud infrastructure providers, and KYC verification services operating internationally.

When personal data is transferred outside the Philippines, 366jl ensures that appropriate safeguards are in place, consistent with the requirements of the Data Privacy Act and NPC guidelines on cross-border data transfers. These safeguards may include:

• Data processing agreements incorporating standard contractual clauses approved or recognized by the National Privacy Commission;
• Transfers to countries or recipients recognized as providing adequate levels of data protection;
• Binding corporate rules where applicable to multinational service providers in our supply chain.

You may request information about the specific safeguards applicable to cross-border transfers of your personal data by contacting our Data Protection Officer at the contact details provided in Section 14.

366jl may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform functionality. Material changes to this Policy will be communicated to registered players via the email address associated with their account and/or via a prominent in-platform notification, with reasonable advance notice prior to the changes taking effect.

The effective date displayed at the top of this document indicates when the current version of the Policy was last reviewed and approved. The current version of this Privacy Policy will always be accessible at https://366jl.co/privacy-policy.

Your continued use of the 366jl platform following the effective date of any Policy update constitutes your acknowledgement of the updated Policy. If you do not agree to the updated Policy, please cease use of the Platform and contact support to close your account.

If you have questions about this Privacy Policy, wish to exercise your data subject rights, or need to report a privacy concern, please contact the 366jl Data Protection Officer through the following channels:

• Email: [email protected] — subject line "Privacy Enquiry" or "Data Subject Request" as appropriate (plain text, not a clickable link)
• Live Chat: Available 24/7 via the chat widget on the 366jl platform
• Response Commitment: General privacy enquiries will receive a response within 48 hours. Formal data subject requests will be acknowledged within five (5) business days and resolved within thirty (30) calendar days of identity verification.

If you are not satisfied with 366jl's response to a privacy concern, or if you believe your rights under the Data Privacy Act have been violated, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines.