Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 368jl, operating the online gaming platform at 368jl.club ("368jl," "we," "us," or "our"), collects, uses, stores, shares, and protects personal information provided by or generated about users ("you," "Player") who access or use any 368jl service.

368jl is committed to handling personal data responsibly and in compliance with the Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC). By registering an account or using any 368jl service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

2. Personal Data We Collect

2.1 Registration & Identity Data

When you create a 368jl account, we collect: full legal name, date of birth, Philippine mobile number, email address (if provided), and a username. During the Know Your Customer (KYC) verification process, we additionally collect copies of government-issued identification documents such as a UMID, Passport, Driver's License, or PhilSys National ID, and where required, proof of address and source of funds documentation.

2.2 Financial & Transaction Data

368jl records all financial transactions conducted through your account, including: deposit amounts, withdrawal requests and amounts, payment method identifiers (e.g. GCash mobile number, BPI or BDO account reference), transaction timestamps, and transaction status. Full payment account numbers are not stored by 368jl — these are handled by the respective payment processors.

2.3 Gameplay & Activity Data

We maintain logs of your gaming activity on 368jl, including: games played, bet amounts, game outcomes, session durations, bonus usage, and responsible gaming tool interactions (e.g., deposit limit settings, self-exclusion requests). This data is used for platform integrity, dispute resolution, responsible gaming monitoring, and regulatory reporting.

2.4 Technical & Device Data

When you access 368jl, we automatically collect: IP address, device type and operating system, browser type and version, referring URL, pages viewed, time and duration of visits, and session identifiers. This data is used for security monitoring, fraud detection, and platform performance optimization.

2.5 Communications Data

If you contact 368jl support, we retain records of your communications, including live chat transcripts, support ticket contents, and any attachments you provide. These records are used to resolve your inquiry and improve customer service quality.

3. How Personal Data Is Collected

368jl collects personal data through the following means:

• Directly from you — through account registration forms, KYC document uploads, deposit and withdrawal requests, support communications, and responsible gaming tool submissions.
• Automatically — through server logs, cookies, and similar tracking technologies when you access 368jl.club via any device.
• From third-party payment processors — transaction confirmation and status data shared by GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners when you conduct financial transactions.
• From identity verification providers — verification outcomes and risk scores returned by KYC and anti-money laundering screening services engaged by 368jl.

4. Purposes of Processing

368jl processes your personal data for the following purposes:

• Creating and administering your 368jl player account.
• Verifying your identity and age (21+ requirement) in compliance with applicable Philippine gaming regulations.
• Processing deposits and withdrawals via GCash, PayMaya, and Philippine bank channels.
• Detecting, investigating, and preventing fraudulent transactions, money laundering, and other prohibited conduct.
• Complying with anti-money laundering (AML) and counter-financing of terrorism (CFT) obligations under Philippine law.
• Administering bonuses, promotions, and loyalty programs.
• Providing customer support and resolving disputes.
• Monitoring and enforcing responsible gaming commitments, including deposit limits and self-exclusion.
• Sending transactional communications, including deposit confirmations, withdrawal notifications, and security alerts to your registered Philippine mobile number.
• Improving the 368jl Platform through analytics and performance monitoring.
• Complying with lawful requests from regulatory bodies, including PAGCOR and the National Privacy Commission.

5. Legal Basis for Processing

368jl processes personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contractual necessity — processing required to perform the contract between you and 368jl (i.e., the Terms and Conditions governing your account).
• Legal obligation — processing required to comply with applicable Philippine laws and regulatory requirements, including AML obligations and PAGCOR reporting requirements.
• Legitimate interests — processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your data protection rights.
• Consent — for marketing communications (where applicable) and cookie usage beyond strictly necessary categories. You may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

6. Sharing of Personal Data

368jl does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following limited circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank receive transaction data necessary to process your deposits and withdrawals.
• Identity verification services: KYC document data is shared with accredited identity verification providers for age and identity confirmation.
• AML screening providers: Name and transaction data may be screened against sanctions lists and politically exposed persons databases.
• Technology service providers: Cloud hosting, data analytics, and customer support platform providers operating under data processing agreements that bind them to confidentiality and security obligations consistent with this Policy.
• Regulatory and law enforcement authorities: 368jl will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities when required by law, court order, or official regulatory request.
• Corporate transactions: In the event of a merger, acquisition, or sale of all or a portion of 368jl's assets, personal data may be transferred as part of the transaction, subject to the receiving party maintaining at least the same level of data protection as this Policy.

7. Data Retention

368jl retains personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations:

• Account registration and KYC data: retained for a minimum of five (5) years after account closure, as required under Philippine AML regulations.
• Transaction records: retained for a minimum of five (5) years from the date of the transaction.
• Gameplay logs: retained for two (2) years from the date of the session, unless required longer for an open dispute or regulatory investigation.
• Support communications: retained for two (2) years from the date of the communication.
• Self-exclusion records: retained for the full duration of the exclusion period plus five (5) years thereafter to prevent circumvention.

Upon expiry of the applicable retention period, 368jl will securely delete or anonymize personal data in accordance with its data disposal procedures.

8. Security Measures

368jl implements a multi-layered security framework to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption in transit: All communications between your browser or device and 368jl.club are encrypted using TLS 1.2 or higher (HTTPS). This protects your login credentials, financial data, and personal information during transmission.
• Encryption at rest: Sensitive personal data stored in 368jl's database systems is encrypted using industry-standard algorithms.
• Access controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis. All access is logged and subject to periodic review.
• Two-factor authentication: 368jl employs OTP-based two-step verification for account login from new devices and high-value financial transactions.
• Security monitoring: 368jl's systems are monitored continuously for anomalous activity, unauthorized access attempts, and potential data breaches.

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 368jl will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular 16-03.

9. Cookies & Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device by a website when you visit it. 368jl uses cookies and similar technologies (such as local storage and session tokens) to operate the Platform and improve your experience.

9.2 Types of Cookies Used by 368jl

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens that keep you logged in to your 368jl account. These cannot be disabled.
• Performance and analytics cookies: Used to understand how Filipino players navigate and use the 368jl Platform, allowing us to identify and fix issues and optimize page performance.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations.

9.3 Managing Cookies

You may manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 368jl Platform, including your ability to remain logged in or access certain features.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), as a registered 368jl player you have the following rights with respect to your personal data:

• Right to be informed: The right to be notified about how your personal data is being collected and processed — as fulfilled by this Policy.
• Right of access: The right to request a copy of the personal data 368jl holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure or blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention requirements.
• Right to object: The right to object to the processing of your personal data on grounds of legitimate interest or for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe 368jl has violated your data privacy rights.

To exercise any of the above rights, please contact 368jl's Data Protection Officer via the support team. We will respond to verified requests within thirty (30) days.

11. Minors

The 368jl Platform is strictly for individuals aged 21 years and above in accordance with Philippine gaming regulations. 368jl does not knowingly collect or process personal data of individuals under the age of 21. If we become aware that personal data has been collected 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 368jl, please notify our support team immediately.

12. International Data Transfers

In certain circumstances, personal data may be transferred to, or processed by, servers or service providers located outside the Republic of the Philippines — for example, where 368jl uses cloud infrastructure or third-party service providers with operations in other countries. Any such transfers are conducted only where adequate safeguards are in place, including contractual data processing agreements that require the recipient to provide a level of data protection consistent with the Data Privacy Act of 2012 and NPC requirements.

13. Changes to This Policy

368jl reserves the right to update or modify this Privacy Policy at any time. Material changes will be communicated to registered players via the Platform notification system or to the mobile number registered on your 368jl account. The effective date of the current version is displayed at the top of this page. Your continued use of the 368jl Platform following notification of material changes constitutes your acceptance of the revised Policy.

14. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 368jl, please contact our Data Protection Officer through the 368jl support team:

You also have the right to contact the National Privacy Commission of the Philippines directly if you believe your data privacy rights have been violated. Information about the NPC and its complaint procedures is publicly available through the NPC's official government channels.