Privacy Policy — 3636 jl

1. Overview

3636 jl ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of every player who uses our services at https://3636jl.org. This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC).

This Privacy Policy applies to all personal information collected through the 3636 jl website, mobile platform, customer support channels, and any other touchpoints where you interact with us. By registering an account or using our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2. Personal Data We Collect

3636 jl collects personal data through several means, including information you provide directly, data generated through your use of the Platform, and information received from third parties. The categories of personal data we collect include:

2.1 Information You Provide Directly

• Full legal name, date of birth, and gender;
• Email address, mobile number, and residential address (including city, province, and postal code);
• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license) submitted for KYC verification;
• Financial information including GCash account details, Maya/PayMaya account details, and Philippine bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for deposit and withdrawal processing;
• Username, password (stored in hashed form), and security question answers;
• Communications you send to our support team via live chat or email.

2.2 Data Generated Automatically

• IP address, device type, operating system, and browser type;
• Geolocation data (country and region level) derived from your IP address;
• Session data including login timestamps, session duration, and pages visited;
• Game activity logs including bets placed, games played, wins, losses, and transaction history;
• Cookies and similar tracking technologies (see Section 6).

2.3 Data from Third Parties

• Identity verification data from KYC/AML service providers;
• Fraud detection signals from payment processors and security partners;
• Publicly available information used to verify your identity or comply with legal obligations.

3. How We Use Your Personal Data

3636 jl processes your personal data for the following purposes:

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 3636 jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions, including account management and payment processing;
• Legal Obligation: Processing required to comply with Philippine laws, including AML/CTF regulations, PAGCOR licensing requirements, and tax obligations;
• Legitimate Interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

3636 jl does not sell your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Processors: GCash, Maya/PayMaya, and Philippine banking partners, solely for processing your financial transactions;
• KYC/AML Providers: Identity verification and anti-money laundering service providers engaged to fulfill our regulatory obligations;
• Game Providers: Third-party game software providers who supply games available on the 3636 jl platform, limited to data necessary for game operation;
• IT & Security Partners: Cloud hosting, cybersecurity, and fraud detection providers operating under strict data processing agreements;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies where disclosure is required by law;
• Legal Proceedings: Courts, law enforcement agencies, or other parties where disclosure is required by a valid legal order or to protect the rights and safety of 3636 jl or its players.

All third-party service providers engaged by 3636 jl are contractually required to process your personal data only for the specified purpose and to maintain appropriate security standards consistent with the Data Privacy Act of 2012.

6. Cookies & Tracking Technologies

3636 jl uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and login state to improve your experience.
• Analytics Cookies: Collect aggregated, anonymized data about how players use the Platform to help us identify areas for improvement.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your explicit consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies in popular browsers, refer to your browser's help documentation.

7. Data Retention

3636 jl retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Our general retention periods are as follows:

• Account Data: Retained for the duration of your account and for five (5) years following account closure, in compliance with AML record-keeping requirements;
• Transaction Records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act;
• KYC Documents: Retained for five (5) years after the end of the business relationship;
• Support Communications: Retained for two (2) years from the date of the last interaction;
• Marketing Consent Records: Retained until you withdraw consent, plus one (1) year for compliance documentation purposes.

When personal data is no longer required, it is securely deleted or anonymized in accordance with our data disposal procedures.

8. Data Security

3636 jl implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data at rest, including financial information and government ID details;
• Passwords stored using one-way cryptographic hashing — we never store your password in plain text;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Multi-factor authentication options for player accounts;
• 24/7 monitoring of our systems for suspicious activity.

9. Your Data Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 3636 jl:

• Right to be Informed: The right to know what personal data we collect and how it is processed — which this Privacy Policy fulfills;
• Right of Access: The right to request a copy of the personal data we hold about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format;
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the details provided in Section 13. We will respond to all verified requests within fifteen (15) business days. We may require proof of identity before processing your request.

10. Minors & Age Restriction

The 3636 jl platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gambling regulations. We do not knowingly collect personal data from individuals under the age of 21.

As part of our KYC verification process, all players are required to submit valid government-issued identification confirming they meet the minimum age requirement before their account is fully activated and before any withdrawal is processed.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, void any transactions, and delete the personal data in question. If you believe a minor has registered on the Platform, please notify us immediately at [email protected].

11. Third-Party Links & Services

The 3636 jl platform may reference or integrate third-party services such as game providers and payment processors. These third parties operate under their own privacy policies, and 3636 jl is not responsible for their data practices.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the 3636 jl platform. Our Privacy Policy applies solely to data collected and processed directly by 3636 jl.

12. Changes to This Privacy Policy

3636 jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or NPC guidance. When material changes are made, we will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page reflects the most recent revision. We encourage you to review this Privacy Policy periodically. Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the changes.

13. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our designated Data Protection Officer (DPO):

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the Platform
• Response Time: We aim to respond to all data privacy requests within 15 business days

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been adequately addressed by 3636 jl.

This Privacy Policy was last reviewed and updated in May 2026. The most current version is always available at https://3636jl.org/privacy-policy.