3636jl Privacy Policy

1 Who We Are

3636jl is the operator of the online gaming platform accessible at https://3636jl.bet. We are the data controller responsible for your personal information as defined under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

As a platform serving Filipino players across the archipelago — from Metro Manila and Makati to Cebu, Davao, and Quezon City — 3636jl is committed to upholding the highest standards of data privacy and information security in every aspect of our operations.

Our designated Data Protection Officer (DPO) oversees all matters relating to data privacy compliance. You may contact our DPO directly at [email protected] for any privacy-related concern, request, or complaint.

2 Personal Data We Collect

3636jl collects personal data that is necessary, relevant, and not excessive in relation to the purposes for which it is collected. The categories of personal data we process are outlined in the table below:

3 How We Collect Your Data

3636jl collects personal data through the following channels:

3.1 Direct Collection

Information you provide directly to us when you: create a 3636jl account; complete identity verification; make deposits or request withdrawals; contact our customer support team; participate in promotions; or respond to surveys and feedback requests.

3.2 Automated Collection

Technical and usage data collected automatically when you access the 3636jl platform, including through cookies, web beacons, pixel tags, server logs, and similar technologies. This includes data about your device, browser, IP address, and how you interact with our games and features.

3.3 Third-Party Sources

We may receive data about you from third parties in specific circumstances, including:

• Payment processors such as GCash and Maya, for the purpose of verifying transaction status.
• Identity verification service providers engaged to assist with KYC compliance.
• Fraud prevention and anti-money laundering screening services.
• PAGCOR and other regulatory bodies, where required by law.

4 How We Use Your Personal Data

3636jl uses your personal data only for legitimate, specified purposes. The primary uses are as follows:

• Account Management: To create, maintain, and administer your 3636jl player account, including processing login requests and managing account settings.
• Identity & Age Verification: To verify that you meet the minimum age requirement of 21 years and to confirm your identity as required by PAGCOR regulations and our KYC obligations.
• Transaction Processing: To process your deposits and withdrawal requests via GCash, Maya, BPI, BDO, Metrobank, and other supported payment channels in Philippine Peso (PHP).
• Regulatory Compliance: To fulfil our legal obligations under Philippine law, including anti-money laundering (AML) requirements, counter-terrorism financing (CTF) laws, and data retention mandates.
• Responsible Gaming: To monitor gaming activity for indicators of problem gambling and to apply responsible gaming tools including deposit limits, session reminders, and self-exclusion where requested or required.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, account takeovers, bonus abuse, and other security threats to the platform and its players.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance through our support channels.
• Platform Improvement: To analyse usage patterns and player behaviour in aggregate, helping us improve the 3636jl gaming experience and identify technical issues.
• Marketing Communications: To send you promotional offers, bonus notifications, and updates about new games — but only where you have provided your consent to receive such communications. You may opt out at any time.

3636jl will not use your personal data for any purpose that is incompatible with those stated above without first obtaining your explicit consent or as otherwise required by law.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173), 3636jl processes your personal data on one or more of the following lawful bases:

• Contractual Necessity: Processing is necessary to perform the contract we have with you — specifically, to operate your player account and deliver the gaming services you have registered to use.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR licensing requirements, AML legislation, and NPC data privacy regulations.
• Legitimate Interests: Processing is necessary for 3636jl's legitimate business interests, including fraud prevention, platform security, and service improvement — provided these interests are not overridden by your data protection rights.
• Consent: For certain processing activities, particularly direct marketing communications, we will seek and rely on your freely given, specific, and informed consent. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

6 Sharing Your Personal Data

3636jl does not sell, lease, or trade your personal data to third parties for their own commercial purposes. We share your data only in the following limited and controlled circumstances:

6.1 Service Providers

We engage trusted third-party service providers who process data on our behalf under binding data processing agreements. These include payment processors (GCash, Maya, local banks), KYC and identity verification providers, IT infrastructure and hosting providers, and customer support platform operators. All such providers are contractually required to maintain the same level of data protection as 3636jl.

6.2 Regulatory & Legal Disclosures

We are required by Philippine law to disclose certain player information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and courts when lawfully requested or required. All such disclosures are made strictly in accordance with applicable legal procedures.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 3636jl's business assets, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and the privacy terms applicable to your data following the transition.

7 Cookies & Tracking Technologies

The 3636jl platform uses cookies and similar tracking technologies to deliver a seamless and personalised gaming experience. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the operation of the platform, including maintaining your login session and enabling secure transactions. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences and settings, such as language selection and game display options, to personalise your 3636jl experience.
• Analytics Cookies: Collect anonymised data about how players navigate the platform, which games are most popular, and where technical issues occur. This information is used in aggregate to improve our services.
• Security Cookies: Used to detect and prevent fraudulent activity, identify suspicious login patterns, and protect account integrity.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 3636jl platform. We do not use third-party advertising cookies or share cookie data with external marketing networks.

8 Data Retention

3636jl retains your personal data only for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Philippine law and regulatory obligations. Key retention periods include:

• Account Data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in accordance with PAGCOR and AML record-keeping requirements.
• Transaction Records: Financial transaction data is retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act of 2001 and its amendments.
• KYC Documents: Identity verification documents are retained for the duration of your account plus five (5) years post-closure.
• Communications Data: Customer support records and correspondence are retained for up to three (3) years from the date of the interaction.
• Technical Logs: Server and access logs are retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised using industry-standard data destruction procedures. Where anonymisation is applied, the resulting data may be retained indefinitely for statistical or analytical purposes, as it can no longer be linked to any individual player.

9 Data Security

3636jl implements a comprehensive, multi-layered security programme to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the 3636jl platform.
• Encryption at rest for all sensitive personal data stored on our servers, including financial details and KYC documents.
• Strict role-based access controls ensuring that personal data is accessible only to authorised personnel with a legitimate business need.
• Regular independent security audits and penetration testing of our platform infrastructure.
• Comprehensive internal data privacy training for all staff who handle personal information.
• Incident response procedures designed to detect, contain, and report data breaches in accordance with NPC notification requirements.

While 3636jl takes every reasonable precaution to protect your data, no online platform can guarantee absolute security. You also play an important role in keeping your account secure — always use a strong, unique password for your 3636jl account and never share your login credentials with anyone.

10 Your Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 3636jl:

To exercise any of the above rights, submit a written request to our Data Protection Officer at [email protected]. We will acknowledge your request within seventy-two (72) hours and provide a substantive response within fifteen (15) business days, as required by NPC guidelines. Requests are processed free of charge unless they are manifestly unfounded, repetitive, or excessive.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11 Children's Privacy

The 3636jl platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. This is both a legal requirement under PAGCOR regulations and a firm ethical commitment of 3636jl.

If we become aware that personal data has been collected from an individual under the age of 21, we will immediately suspend the associated account, delete the relevant data, and take all necessary steps to prevent further access. Age verification is a mandatory step in the 3636jl registration process for this reason.

If you believe that a minor has accessed or registered on the 3636jl platform, please contact us immediately at [email protected] so that we can investigate and take appropriate corrective action.

12 Cross-Border Data Transfers

In some cases, your personal data may be transferred to, stored in, or processed in a country outside the Philippines — for example, where our third-party service providers operate data centres in other jurisdictions. Any such cross-border transfer of personal data is conducted only where:

• The recipient country has been assessed as providing an adequate level of data protection comparable to Philippine standards.
• Appropriate contractual safeguards are in place, such as data processing agreements incorporating the standard contractual clauses approved by the National Privacy Commission.
• The transfer is necessary for the performance of a contract with you, such as processing a payment through an international payment network.

3636jl remains responsible for ensuring that any third party receiving your personal data maintains protection standards consistent with this Privacy Policy and applicable Philippine data privacy law.

13 Amendments to This Policy

3636jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, new regulatory requirements, or improvements to our privacy programme. The date of the most recent revision is shown at the top of this page.

Where amendments are material — meaning they significantly affect your rights or our obligations — we will notify registered players via the email address on file before the changes take effect. For minor clarifications or administrative updates, posting the revised policy on this page constitutes sufficient notice.

Your continued use of the 3636jl platform following the effective date of any amendment constitutes your acknowledgement of the updated Privacy Policy. If you disagree with any changes, you should discontinue use of the platform and contact us to close your account.

14 Contact Us & Data Protection Officer

For any questions, concerns, or formal requests relating to this Privacy Policy or the handling of your personal data by 3636jl, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Please mark your email "Privacy Request" or "DPO Enquiry" so it reaches the right team promptly.
• Response Time: Acknowledgement within 72 hours; substantive response within 15 business days.
• Live Support: Available 24/7 via the live chat feature on the 3636jl platform for general privacy questions.

You also have the right to file a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated and have not been adequately addressed by 3636jl.