36jll Privacy Policy

1. Overview

36jll operates an online gaming platform serving players in the Philippines. As part of running this platform, we collect and process personal data from registered users and visitors to our website. This Privacy Policy sets out what information we gather, why we gather it, and how we handle it responsibly.

By creating an account on 36jll or using our website and mobile app, you acknowledge that you have read and understood this policy. We encourage all players — whether you're based in Manila, Cebu, Davao, or anywhere else in the Philippines — to read through this document before registering.

2. Information We Collect

We collect different types of information depending on how you interact with the platform. The main categories are:

We only collect information that is necessary for the operation of the platform or required to meet our legal and security obligations. We do not collect sensitive personal data beyond what is needed for KYC compliance and age verification.

3. How We Use Your Information

Your data is used strictly for the purposes connected to operating a safe and fair gaming platform. The specific purposes are:

• Account management — Creating and maintaining your player account, processing logins, and enabling account recovery.
• Identity and age verification — Confirming that you are who you say you are and that you meet the 21+ age requirement before allowing gameplay and withdrawals.
• Payment processing — Facilitating PHP deposits and withdrawals via bank transfer, GCash, or Maya, and maintaining accurate financial records.
• Platform security — Detecting and preventing fraud, unauthorised access, money laundering, and other prohibited activities.
• Responsible gaming — Monitoring usage patterns to support players who use deposit limits, session controls, or self-exclusion tools.
• Customer support — Responding to your queries, disputes, and requests accurately and efficiently.
• Platform improvement — Analysing aggregate usage data to improve site performance, game availability, and the overall player experience.
• Legal compliance — Meeting obligations under applicable Philippine laws and regulations, including record-keeping and reporting requirements.

We do not use your personal data for purposes beyond those listed above without your prior consent. We do not sell your data to advertisers or third-party marketing companies.

4. Data Sharing and Third Parties

36jll does not sell or rent your personal information to third parties. However, we do share data with certain service providers and partners where it is necessary to operate the platform:

• Payment processors — Your financial information is shared with banks and e-wallet platforms to complete transactions. These providers operate under their own security and compliance standards.
• Identity verification providers — KYC checks may involve third-party verification services that compare your submitted documents against verification databases.
• Fraud prevention services — Anonymised or flagged account data may be shared with fraud detection systems to protect the platform.
• Technology and infrastructure providers — Our hosting, security, and analytics infrastructure involves trusted vendors who are contractually required to handle your data securely.
• Legal and regulatory authorities — We will disclose information when required by law, regulation, or court order.

5. How We Protect Your Data

Data security is built into how 36jll operates. The platform uses a combination of technical and administrative controls to protect your information:

• SSL encryption — All data transmitted between your device and the 36jll platform is protected using Secure Socket Layer (SSL) encryption. This applies to both the website and mobile app.
• OTP authentication — One-time password verification is used during login and sensitive account actions to confirm your identity and prevent unauthorised access.
• Access controls — Internal access to player data is restricted on a need-to-know basis. Staff handling personal data are trained on data handling obligations.
• Secure payment handling — Financial transaction data is processed through secure payment channels. 36jll does not store full bank account or card credentials on its own servers.
• Regular security monitoring — Platform activity is monitored continuously for unusual patterns that may indicate fraud, hacking attempts, or account compromise.

While we take every reasonable precaution, no online system can guarantee absolute security. You are also responsible for keeping your login credentials, password, and OTP codes confidential. Do not share these with anyone.

6. Data Retention

We retain your personal data for as long as your account is active and for a period after closure to meet our legal and financial record-keeping obligations. The general retention periods are:

• Account and identity data — Retained for the duration of your account and for a minimum period after closure as required by applicable Philippine laws.
• Transaction records — Financial records are retained for a minimum of five years to comply with anti-money laundering and financial reporting obligations.
• Support communications — Records of support interactions are kept for a reasonable period to assist with dispute resolution and quality assurance.
• Technical and device data — Log data and session records are retained for a shorter period and used primarily for security and fraud prevention purposes.

When data is no longer required for its original purpose and there is no legal obligation to retain it, we take reasonable steps to securely delete or anonymise it.

7. Your Rights as a Player

As a registered player on 36jll, you have rights over your personal data. These include:

• Right to access — You may request a copy of the personal data we hold about you at any time.
• Right to correction — If any of your personal information is inaccurate or outdated, you can request that we correct it.
• Right to deletion — You may request deletion of your personal data, subject to our legal retention obligations. Requests for deletion will be reviewed against applicable requirements before action is taken.
• Right to restrict processing — In certain circumstances, you may ask us to limit how we use your data while a concern is being reviewed.
• Right to data portability — Where technically feasible, you may request your data in a structured, commonly used format.

To exercise any of these rights, contact the 36jll support team using the email address provided in the footer of this page. We will acknowledge your request and respond within a reasonable timeframe. Some requests may require identity verification before they can be processed.

8. Cookies and Tracking

36jll uses cookies and similar tracking technologies to improve your experience on the platform. Cookies are small text files stored on your device that help us recognise you across sessions and understand how the platform is being used.

The types of cookies we use include:

• Essential cookies — Required for the platform to function. These handle session management, login state, and security tokens. The platform cannot work properly without them.
• Performance cookies — Collect anonymised data about how players navigate the site, which pages are most visited, and where errors occur. This information helps us improve the platform.
• Functional cookies — Remember your preferences such as language settings and game display options to personalise your experience.

Most browsers allow you to manage cookie preferences through your settings. Disabling essential cookies may prevent you from logging in or using key platform features. We do not use cookies to serve third-party advertising or track your activity outside the 36jll platform.

9. Minors and Age Verification

The 36jll platform is strictly for players aged 21 years and above. We do not knowingly collect personal data from anyone under this age. Age verification is part of our registration and KYC process — we may request a government-issued ID or other proof of age to confirm eligibility.

If we become aware that personal data has been collected from a person under 21, we will take steps to delete that information and close the associated account promptly. If you believe a minor has registered on the platform, please contact our support team immediately.

10. Updates to This Policy

36jll may update this Privacy Policy from time to time to reflect changes in how we operate, legal requirements, or the features available on the platform. When material changes are made, the "Last updated" date at the top of this page will be revised. Where appropriate, we will also notify registered players via email or in-platform message.

We encourage you to review this policy periodically. Continued use of the 36jll platform after any update constitutes acceptance of the revised policy. If you have concerns about any changes, contact our support team or request account closure before the updated policy takes effect.