936jl Privacy Policy — How We Collect, Use, and Protect Your Data

936jl ("936jl," "we," "us," or "our") operates the online gaming platform accessible at https://936jl.net and through the 936jl mobile application (collectively, the "Platform"). We are committed to protecting the privacy and personal data of every player who registers on or uses the 936jl Platform.

This Privacy Policy ("Policy") describes how 936jl collects, uses, stores, shares, and protects personal information in connection with the operation of the Platform. It applies to all registered players, visitors, and any individual who interacts with the 936jl Platform in any capacity, including players based in Manila, Cebu, Davao, Quezon City, Makati, and across the Philippine archipelago.

This Policy is issued in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission ("NPC"). 936jl takes its obligations under the DPA seriously and has implemented appropriate technical and organizational measures to ensure the security and confidentiality of all personal data it processes.

This Policy should be read alongside 936jl's Terms and Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and 936jl.

936jl collects personal data that is necessary for the operation of the Platform, the provision of gaming services, compliance with regulatory obligations, and the protection of both players and the Platform from fraud and financial crime. The categories of personal data we collect include:

• Full legal name as it appears on a government-issued identification document
• Date of birth (used to verify that you meet the 21+ age requirement)
• Residential address, including barangay, city or municipality, province, and postal code
• Email address and mobile phone number
• Username and encrypted password
• Nationality and country of residence

• Government-issued photo identification (e.g., Philippine National ID, passport, driver's licence, SSS/GSIS ID, Voter's ID)
• Proof of residential address (e.g., utility bill, bank statement, barangay certificate)
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account, bank statement from BPI, BDO, or Metrobank)
• Selfie or live photo for biometric identity verification where required

• Deposit and withdrawal transaction records, including amounts, dates, and payment method references
• Payment method details (e.g., GCash mobile number, PayMaya account reference, bank account name and last four digits)
• Bonus and promotional activity records
• Account balance history and wagering records

• IP address and approximate geolocation derived from IP
• Device type, operating system, browser type and version
• Session duration, login timestamps, and Platform navigation data
• Game play history, including games accessed, wagers placed, and outcomes
• Mobile application version and device identifiers

• Records of communications between you and 936jl customer support, including live chat transcripts, email correspondence, and support ticket history
• Survey responses and feedback submitted through the Platform
• Marketing preference settings and communication opt-in or opt-out records

936jl collects personal data through the following means:

• Directly from you: When you complete the registration form, submit KYC verification documents, make a deposit or withdrawal, contact customer support, or respond to a survey or promotion on the 936jl Platform.
• Automatically: When you access the Platform, our servers and analytics systems automatically collect technical data such as your IP address, device information, session data, and browsing behaviour within the Platform.
• Through cookies and similar technologies: The 936jl Platform uses cookies, web beacons, and similar tracking technologies to collect usage data and improve the player experience. See Section 9 for full details on our cookie practices.
• From third-party service providers: We may receive data from identity verification providers, payment processors (including GCash, PayMaya, BPI, BDO, and Metrobank), fraud detection services, and analytics partners in connection with the operation of the Platform.
• From regulatory and law enforcement sources: In limited circumstances, we may receive data from PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other regulatory or law enforcement bodies in connection with our compliance obligations.

936jl processes your personal data for the following specific, legitimate purposes:

936jl will not process your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing another lawful basis for processing.

936jl processes personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing is necessary for the performance of the contract between you and 936jl, including account registration, payment processing, and the provision of gaming services.
• Legal obligation: Processing is required for 936jl to comply with applicable laws and regulations, including PAGCOR licensing requirements, AML obligations under Republic Act No. 9160 (Anti-Money Laundering Act), and KYC requirements.
• Legitimate interests: Processing is necessary for the legitimate interests of 936jl, including fraud prevention, platform security, responsible gaming monitoring, and business analytics, provided that such interests are not overridden by your rights and freedoms.
• Consent: Where 936jl relies on your consent as the legal basis for processing — for example, for direct marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

936jl 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

936jl engages third-party service providers to assist in the operation of the Platform. These include identity verification and KYC providers, payment processors (including GCash, PayMaya, BPI, BDO, and Metrobank), cloud hosting and infrastructure providers, customer support platform providers, fraud detection and cybersecurity services, and analytics providers. All third-party processors are contractually bound to process personal data only on 936jl's instructions and in accordance with applicable data protection law.

936jl may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), or other competent Philippine government authorities where required by law, court order, or regulatory directive. Such disclosures are made only to the extent required and in accordance with applicable legal procedures.

In the event of a merger, acquisition, restructuring, or sale of all or part of 936jl's business, personal data held by 936jl may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and of any material changes to data processing practices that may result from it.

936jl retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with 936jl's data disposal procedures. Where data is anonymised rather than deleted, the resulting anonymised data may be retained indefinitely for analytical purposes, as it no longer constitutes personal data.

936jl implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the 936jl Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data stored in our systems is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorized 936jl personnel and service providers on a strict need-to-know basis. All access is logged and subject to regular audit.
• Two-factor authentication: 936jl offers and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Penetration testing and vulnerability management: 936jl conducts regular security assessments, including penetration testing and vulnerability scanning, to identify and remediate potential security weaknesses in the Platform.
• Incident response: 936jl maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, 936jl will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

The 936jl Platform uses cookies and similar tracking technologies to enhance your experience, maintain session state, prevent fraud, and collect analytics data. The following types of cookies are used:

• Strictly necessary cookies: These cookies are essential for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled without impairing Platform functionality.
• Functional cookies: These cookies remember your preferences and settings, such as language preferences and responsible gaming limit configurations, to provide a more personalized experience.
• Analytics cookies: These cookies collect aggregated, anonymised data about how players use the Platform, including pages visited, session duration, and navigation paths. This data is used to improve Platform performance and user experience.
• Security and fraud prevention cookies: These cookies help 936jl detect and prevent fraudulent activity, including the use of multiple accounts, automated bots, and suspicious login patterns.

You may manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect the functionality of the 936jl Platform. 936jl does not use cookies to serve third-party advertising or to track your activity on websites outside of the 936jl Platform.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 936jl:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfils that obligation.
• Right of access: You have the right to request a copy of the personal data that 936jl holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request the correction of any inaccurate or incomplete personal data that 936jl holds about you. You may update certain account information directly through your 936jl account settings.
• Right to erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 936jl's legal and regulatory retention obligations.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to 936jl's overriding legitimate grounds.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 936jl has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact 936jl's Data Protection Officer using the contact details provided in Section 14 of this Policy. 936jl will respond to all verified data rights requests within thirty (30) days of receipt, in accordance with the requirements of the DPA.

The 936jl Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations administered by PAGCOR. 936jl does not knowingly collect personal data from individuals under the age of 21.

If 936jl becomes aware that personal data has been collected from an individual who is under 21 years of age, it will take immediate steps to close the associated account, delete the personal data, and, where applicable, return any deposits in accordance with applicable regulations. Any winnings accrued by an underage player will be forfeited.

If you are a parent or guardian and believe that your child has registered on the 936jl Platform, please contact our support team immediately using the contact details in Section 14.

The 936jl Platform may contain references to third-party payment services such as GCash, PayMaya, BPI, BDO, and Metrobank, which are accessed through their own separate platforms and interfaces. 936jl is not responsible for the privacy practices of these third-party services. We encourage you to review the privacy policies of any third-party service you use in connection with your 936jl account.

936jl does not embed third-party advertising networks, social media tracking pixels, or external analytics services that would transmit your personal data to third parties for advertising or profiling purposes outside of the 936jl Platform.

936jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The effective date of the current version is displayed at the top of this Policy.

Where changes are material — meaning they significantly affect your rights or the way 936jl processes your personal data — 936jl will provide advance notice to registered players via email or a prominent notice on the Platform, no less than fourteen (14) days before the changes take effect. Your continued use of the 936jl Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 936jl protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 936jl, please contact our Data Protection Officer. Our support team is available 24 hours a day, 7 days a week, and is staffed by Filipino-English speaking agents.

If you are not satisfied with 936jl's response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available through official Philippine government channels.