396jl Privacy Policy

1. Introduction

396jl ("we," "us," or "our") is committed to protecting the privacy and personal data of all users ("you" or "Player") who access and use the 396jl online casino and sports betting platform (the "Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

This policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). It should be read together with our Terms & Conditions and Responsible Gaming Policy.

By creating a 396jl account, accessing the Platform, or otherwise providing us with your personal information, you consent to the collection and processing of your data as described in this Privacy Policy.

2. Data We Collect

396jl collects the following categories of personal data from users of the Platform:

We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required for responsible gaming assessments or regulatory compliance.

3. How We Collect Your Data

396jl collects personal data through the following means:

• Direct Interactions: When you register an account, complete identity verification (KYC), make a deposit or withdrawal, contact customer support, or participate in promotions.
• Automated Technologies: When you browse or use the Platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies.
• Third-Party Sources: We may receive data about you from payment processors (e.g., GCash, PayMaya), identity verification service providers, fraud prevention agencies, and analytics partners.
• Publicly Available Sources: In limited circumstances, we may collect information from publicly available sources to verify your identity or comply with anti-money laundering obligations.

4. How We Use Your Data

396jl uses your personal data for the following purposes:

• To create, verify, and manage your 396jl account.
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP).
• To verify your identity and age (21+) in compliance with Philippine gaming regulations.
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities.
• To personalize your gaming experience and deliver relevant promotions and offers.
• To provide customer support and respond to your enquiries.
• To send you service-related communications, including account notifications and security alerts.
• To comply with our legal and regulatory obligations under Philippine law.
• To analyze Platform usage and improve our products, services, and user experience.
• To enforce our Terms & Conditions and other applicable policies.

396jl will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 396jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your account and provide gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations and gaming licensing requirements.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights.
• Consent: For certain processing activities, such as marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

6. Data Sharing and Disclosure

396jl does not sell your personal data. We may share your 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, to process your financial transactions.
• Identity Verification Providers: Third-party KYC and age verification services used to confirm your identity and eligibility.
• Fraud Prevention and Security Services: Providers that help us detect and prevent fraudulent activity on the Platform.
• Analytics Providers: Service providers that help us understand how the Platform is used, strictly for internal improvement purposes.
• Regulatory Authorities: Philippine government agencies, including the National Privacy Commission, and gaming regulators, where disclosure is required by law or court order.
• Professional Advisers: Lawyers, auditors, and other professional advisers bound by confidentiality obligations.

All third-party service providers who process personal data on our behalf are required to implement appropriate technical and organizational security measures and to process data only in accordance with our instructions.

7. Cookies and Tracking Technologies

396jl uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled as they are required for core features such as account login and session management.
• Performance Cookies: Collect anonymized data about how users interact with the Platform, helping us identify areas for improvement.
• Functional Cookies: Remember your preferences (such as language settings and display options) to provide a more personalized experience.
• Targeting/Analytics Cookies: Used to analyze usage patterns and measure the effectiveness of our content. These are only set with your consent.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 396jl Platform. For more information on managing cookies, refer to your browser's help documentation.

8. Data Retention

396jl retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering regulations.
• Financial Transaction Data: Retained for a minimum of five (5) years from the date of the transaction.
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session.
• Communications Data: Support correspondence is retained for two (2) years from the date of the last interaction.
• Technical and Usage Data: Retained for up to twelve (12) months from collection.

Upon expiry of the applicable retention period, your personal data will be sec urely deleted or anonymized in accordance with our data disposal procedures.

9. Data Security

396jl implements industry-standard technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the 396jl Platform is encrypted in transit.
• Encrypted Data Storage: Sensitive data, including financial information and identity documents, is encrypted at rest on our servers.
• Access Controls: Access to personal data is restricted to authorized 396jl personnel and service providers on a strict need-to-know basis.
• Two-Factor Authentication: Available for all 396jl accounts to provide an additional layer of login security.
• Regular Security Audits: Our systems and processes are subject to periodic security assessments and penetration testing.
• Incident Response: In the event of a personal data breach, 396jl will notify affected users and the National Privacy Commission within the timeframes required by the Data Privacy Act of 2012.

While we take all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for keeping your account credentials confidential and for notifying us immediately of any suspected unauthorized access.

10. Your Rights

Under the Data Privacy Act of 2012, 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 about how your personal data is collected and processed, as set out in this Privacy Policy.
• Right of Access: You may request a copy of the personal data we hold about you at any time.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days of receipt.

11. Children's Privacy

The 396jl Platform is strictly intended for users who are 21 years of age or older, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that we have inadvertently collected personal data from a person under 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the 396jl Platform, please contact us immediately at [email protected].

12. International Data Transfers

396jl primarily stores and processes personal data within the Philippines. In limited circumstances, data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international fraud prevention services.

Where such transfers occur, 396jl ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses that meet the standards required by the Data Privacy Act of 2012 and the National Privacy Commission.

By using the 396jl Platform, you consent to the transfer of your personal data to countries outside the Philippines where necessary for the purposes described in this policy, provided that adequate protections are in place.

13. Policy Updates

396jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or business operations. When material changes are made, we will notify registered users via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information. Your continued use of the 396jl Platform following any update constitutes your acceptance of the revised policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact the 396jl Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 through the 396jl Platform
• Response Time: All data-related requests are acknowledged within 5 business days and resolved within 30 days.

You also have the right to file a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. Visit the NPC's official channels for guidance on how to submit a complaint.