35jl Casino — Privacy Policy

01 Introduction

This Privacy Policy ("Policy") explains how 35jl ("35jl," "the Platform," "we," "us," "our") collects, uses, discloses, stores, and protects personal information about individuals ("you," "Player," "User") who access or use the 35jl website at 35jl.org and all associated services (collectively, the "Service").

35jl is committed to protecting the privacy and security of your personal data. We process your personal information in accordance with the Republic of the Philippines Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and other applicable Philippine laws and regulations.

By registering an account with 35jl or using any part of the Service, you acknowledge that you have read and understood this Policy. This Policy should be read together with our Terms & Conditions. If you do not agree with the terms of this Policy, please do not use the Service.

02 Data Controller

For the purposes of the Data Privacy Act of 2012, 35jl is the personal information controller in respect of the personal data collected through the Service. As the personal information controller, 35jl determines the purpose and means of processing your personal data.

35jl has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data protection laws and responding to data subject requests. Inquiries relating to the processing of your personal data may be directed to the 35jl support team, who will route them to the DPO as appropriate.

03 Personal Data We Collect

35jl collects the following categories of personal data in connection with your use of the Service:

We do not knowingly collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. We do not collect biometric data except where provided voluntarily as part of a government-issued identification document submitted for KYC purposes.

04 How We Use Your Personal Data

35jl uses the personal data we collect for the following purposes:

• Account Creation and Management: To create and maintain your 35jl account, verify your identity, and provide you with access to the Service;
• Transaction Processing: To process deposits and withdrawals through GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels, and to maintain accurate records of all financial transactions;
• Legal and Regulatory Compliance: To fulfil our obligations under anti-money laundering (AML) regulations, PAGCOR licensing conditions, and other applicable laws, including the retention of records as required by law;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the platform;
• Responsible Gaming: To monitor gaming activity, enforce responsible gaming tools you have set (such as deposit limits or self-exclusion), and identify players who may require support;
• Customer Support: To respond to your enquiries, resolve disputes, and improve the quality of our support services;
• Marketing Communications: Where you have provided consent, to send you promotional offers, platform updates, and information about new games or features at 35jl. You may opt out at any time;
• Platform Improvement: To analyse usage patterns, identify technical issues, and develop improvements to the 35jl Service.

05 Legal Bases for Processing

Under the Data Privacy Act of 2012, 35jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil our agreement with you under the 35jl Terms & Conditions, including account management and transaction processing;
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML obligations and regulatory record-keeping requirements;
• Legitimate Interests: Processing necessary for the legitimate interests of 35jl, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your fundamental rights;
• Consent: Where you have provided explicit consent, including for the receipt of marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

06 Data Sharing and Disclosure

35jl does not sell or rent your personal data. We may share your personal data with third parties only in the following limited circumstances:

• Service Providers: Third-party vendors who assist in operating the 35jl platform, including payment processors (e.g., GCash, PayMaya, banking partners), game software providers, KYC verification services, fraud detection providers, and cloud hosting infrastructure. All service providers are bound by data processing agreements and may only use your data for the purposes specified by 35jl;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, and other government bodies where disclosure is required by law, court order, or regulatory demand;
• Corporate Transactions: In connection with a merger, acquisition, or sale of assets involving 35jl, personal data may be transferred as part of the transaction. Players will be notified of any such transfer and any change in the identity of the data controller;
• Protection of Rights: Where disclosure is necessary to protect the rights, property, or safety of 35jl, its players, or the public.

07 Cookies and Tracking Technologies

35jl uses cookies and similar tracking technologies on its platform. Cookies are small data files placed on your browser or device that help the platform function correctly and enable us to understand how the Service is used.

We use the following types of cookies:

• Strictly Necessary Cookies: Required for the platform to function (e.g., maintaining your login session, remembering your language preference). These cannot be disabled without impairing the core functionality of the Service;
• Analytics Cookies: Used to collect aggregated, anonymised information about how players use the 35jl platform, helping us identify areas for improvement;
• Functionality Cookies: Store preferences you have set within the platform (e.g., game settings, display preferences) to enhance your experience;
• Security Cookies: Support fraud detection and account security monitoring functions.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may affect your ability to use certain features of the 35jl Service.

08 Data Retention

35jl retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to applicable legal retention obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLC record-keeping requirements;
• KYC and Identity Verification Records: Retained for a minimum of five (5) years from the date of the last transaction, as required by anti-money laundering regulations;
• Transaction Records: Retained for a minimum of five (5) years;
• Customer Support Communications: Retained for three (3) years from the date of the interaction;
• Marketing Consent Records: Retained until consent is withdrawn plus three (3) years thereafter as evidence of prior consent.

At the end of the applicable retention period, data is securely deleted or anonymised in a manner that prevents re-identification.

09 Data Security

35jl implements a range of technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS 1.3 encryption for all data transmitted between your device and 35jl servers;
• Encryption of personal data stored in 35jl databases using industry-standard algorithms;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Two-factor authentication requirements for access to administrative systems;
• Regular security audits and vulnerability assessments of platform infrastructure;
• Employee training on data protection obligations and security best practices.

In the event of a personal data breach that is likely to result in harm to affected individuals, 35jl will notify the National Privacy Commission and affected data subjects within the timeframe required by applicable law.

10 Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 35jl:

• Right to Be Informed: The right to be informed of how your personal data is being processed, as set out in this Privacy Policy;
• Right of Access: The right to request a copy of the personal data 35jl holds about you;
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to applicable legal retention obligations;
• Right to Object: The right to object to the processing of your personal data where processing is based on legitimate interests, including the right to opt out of direct marketing at any time;
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe 35jl has not processed your personal data in accordance with the Data Privacy Act.

To exercise any of these rights, please contact the 35jl support team. We will respond to verified requests within thirty (30) days. We may need to verify your identity before processing your request.

11 Children's Privacy

The 35jl platform is strictly for individuals aged 21 years and above. 35jl does not knowingly collect personal data from persons under the age of 21. If we discover that we have inadvertently collected personal data from a person under 21, we will delete that data immediately and close the associated account.

If you believe that a person under the age of 21 has registered an account with 35jl, please contact our support team immediately so that the matter can be investigated and resolved.

12 International Data Transfers

35jl's primary operations and data storage infrastructure are located in the Philippines. In some circumstances, personal data may be transferred to or accessed by service providers located outside the Philippines — for example, cloud infrastructure providers or software vendors operating internationally.

Where such transfers occur, 35jl takes appropriate steps to ensure that your personal data receives an equivalent level of protection as it would under Philippine law, including through contractual safeguards with receiving parties. We do not transfer personal data to third countries that do not provide an adequate level of data protection without appropriate safeguards in place.

13 Changes to This Privacy Policy

35jl may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform operations. Material changes will be communicated to registered players via the contact details on file at least fourteen (14) days before they take effect. The updated effective date will be displayed at the top of this page.

Your continued use of the 35jl Service after the effective date of any revised Privacy Policy constitutes your acknowledgement of and agreement to the updated terms. If you do not agree with a revised Policy, you should cease using the Service and may request account closure.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 35jl, please contact us through the following channel:

• Live Chat: Available 24/7 inside your 35jl account dashboard — the fastest way to reach our data protection team;
• Email: [email protected] — please mark your email subject line with "Data Privacy Request" for prompt routing to our Data Protection Officer.

If you are not satisfied with our response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.