3jlp Privacy Policy

1 Introduction and Scope

1.1  This Privacy Policy ("Policy") applies to all personal information collected, stored, used, shared, and otherwise processed by the 3jlp online casino platform ("3jlp," "we," "us") in connection with your use of the 3jlp website, mobile-accessible platform, and all associated services operated under the domain 3jlp.one.

1.2  This Policy applies to all current and former Members of the 3jlp platform, applicants whose registration was not completed, and visitors to the 3jlp website regardless of whether a registered account exists. By accessing the 3jlp platform, you acknowledge that you have read and understood this Policy.

1.3  This Policy does not apply to third-party websites, applications, or services that may be linked from the 3jlp platform. 3jlp is not responsible for the privacy practices of third-party game providers or payment processors beyond the scope described in Section 7 of this Policy.

1.4  This Policy should be read alongside 3jlp's Terms and Conditions and Responsible Gaming Policy, which together form the complete framework governing your use of the 3jlp platform.

2 Data Controller

2.1  For the purposes of the Data Privacy Act of 2012, 3jlp acts as the Personal Information Controller with respect to all personal data collected from Members and users of the 3jlp platform. As Controller, 3jlp determines the purposes and means of processing personal data described in this Policy.

2.2  3jlp has designated a Data Protection Officer (DPO) as required under the DPA. The DPO is responsible for overseeing compliance with this Policy and with the requirements of RA 10173. Contact details for the DPO are provided in Section 16 of this Policy.

2.3  Certain third-party service providers engaged by 3jlp — including payment processors and game content suppliers — process personal data as Personal Information Processors on behalf of 3jlp, subject to contractual obligations that ensure an equivalent level of data protection to that described in this Policy.

3 Categories of Personal Data We Collect

3jlp collects the following categories of personal data from Members and platform users, to the extent necessary and proportionate to the purposes described in Section 5:

3jlp does not intentionally collect special categories of sensitive personal information — including health data, religious beliefs, political opinions, or racial or ethnic origin — unless directly and necessarily relevant to a specific support or responsible gaming context, and only with your explicit consent.

4 How We Collect Your Personal Data

3jlp collects personal data through the following means:

• Directly from you: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or updating your account settings.
• Automatically during platform use: Technical and gaming activity data collected through cookies, server logs, and platform analytics during each session on 3jlp. See Section 11 for full cookie details.
• From payment service providers: Transaction confirmation data from GCash, PayMaya, BDO, BPI, Metrobank, and other integrated payment channels, received in the course of processing deposits and withdrawals.
• From identity verification services: Results of automated identity document verification checks conducted as part of the KYC process, including government database cross-referencing where permitted under Philippine law.
• From fraud and compliance monitoring systems: Risk signals, device fingerprinting, and pattern analysis conducted to detect and prevent fraud, money laundering, and multi-accounting in compliance with RA 9160.

5 Purposes of Processing

3jlp processes your personal data only for the following specified, explicit, and legitimate purposes:

• Creating and managing your 3jlp account and verifying your identity and age for KYC compliance;
• Processing deposits, withdrawals, and maintaining your account transaction history;
• Providing access to all game categories on the 3jlp platform and maintaining accurate records of game activity;
• Detecting, preventing, and investigating fraud, collusion, multi-accounting, money laundering, and other prohibited activities as defined in the 3jlp Terms and Conditions and RA 9160;
• Complying with reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other relevant Philippine regulatory authorities;
• Administering bonuses, promotions, and the VIP loyalty programme;
• Operating responsible gaming tools including deposit limits, self-exclusion, and session controls;
• Providing customer support and resolving disputes;
• Sending account-related communications including transaction confirmations, security alerts, and policy updates;
• Sending promotional and marketing communications to Members who have not opted out, in accordance with their registered contact preferences;
• Improving the 3jlp platform through aggregate analytics and user experience research.

6 Legal Bases for Processing

Under the Data Privacy Act of 2012, 3jlp processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and 3jlp — specifically, the provision of gaming services, account management, and payment processing as described in the Terms and Conditions;
• Legal obligation: Processing required to comply with RA 9160 (Anti-Money Laundering Act), PAGCOR regulatory requirements, NPC requirements, and other applicable Philippine laws;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests do not override your privacy rights;
• Consent: Processing for marketing communications and optional platform features, where consent is the appropriate basis. You may withdraw consent for marketing at any time via your account settings without affecting other processing.

7 Disclosure of Personal Data to Third Parties

7.1  3jlp does not sell, rent, or otherwise commercially disclose your personal data to third parties. Data is shared with the following categories of recipients only to the extent strictly necessary:

• Payment service providers (GCash, PayMaya, BDO, BPI, Metrobank, and cryptocurrency processors) — for processing deposits and withdrawals to and from your registered payment method;
• Game content providers (including JILI, PG Soft, Pragmatic Play, Spadegaming, and similar suppliers) — to the extent necessary to record game session results and RNG certification data;
• Identity verification and KYC service providers — to validate the authenticity of government-issued identification documents submitted during registration;
• Fraud detection and anti-money laundering compliance systems — for transaction monitoring and risk assessment as required under RA 9160;
• Philippine regulatory and law enforcement authorities — including PAGCOR, AMLC, NPC, and any court of competent jurisdiction, where legally required or ordered;
• IT infrastructure and hosting providers — contracted on a data processor basis with contractual data protection obligations equivalent to this Policy.

7.2  All third-party recipients of personal data are bound by contractual obligations to process such data only for the purposes described above and to maintain security standards consistent with this Policy. 3jlp remains responsible for the protection of data shared with processors acting on its behalf.

8 International Data Transfers

8.1  Some of 3jlp's game content providers and infrastructure partners maintain servers or processing facilities outside the Philippines. Where your personal data is transferred to entities in other jurisdictions, 3jlp ensures that such transfers are subject to appropriate safeguards, including contractual data protection clauses that provide a level of protection equivalent to the Data Privacy Act of 2012.

8.2  3jlp will not transfer your personal data to a jurisdiction that does not provide adequate data protection safeguards without your explicit prior consent, unless required to do so by a mandatory legal obligation under Philippine law.

9 Data Retention

9.1  3jlp retains your personal data for the following periods, unless a longer retention period is required by applicable Philippine law:

• Account and identity data: For the duration of your active 3jlp account, and for a minimum of five (5) years following permanent account closure — as required for anti-money laundering compliance under RA 9160;
• Financial transaction records: For a minimum of five (5) years from the date of the transaction, in compliance with AMLC record-keeping requirements;
• Gaming activity records: For a minimum of two (2) years from the date of the session, for dispute resolution and regulatory audit purposes;
• Communications and support records: For a minimum of two (2) years from the date of the interaction;
• Marketing consent records: For the duration of your active account and for one (1) year following opt-out or account closure, to evidence compliance with consent-based processing obligations.

9.2  Upon expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymised. Anonymised aggregate data — from which you cannot be identified — may be retained indefinitely for platform analytics and improvement purposes.

10 Security Measures

3jlp implements the following technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 3jlp servers;
• Encryption at rest for sensitive data stored in 3jlp databases, including KYC documents and financial identifiers;
• Role-based access controls limiting internal data access to personnel with a legitimate, documented business need;
• Two-factor authentication (2FA) enforced for internal administrative systems and available to Members for account access;
• Regular penetration testing and vulnerability assessments of the 3jlp platform and supporting infrastructure;
• Intrusion detection and anomaly monitoring systems covering all production environments;
• Staff training and data protection awareness programmes conducted at onboarding and periodically throughout employment.

Notwithstanding the above measures, no electronic data transmission or storage system can be guaranteed to be completely secure. 3jlp encourages Members to use strong, unique passwords and to enable 2FA on their accounts as an additional personal security measure.

11 Cookies and Tracking Technologies

11.1  The 3jlp platform uses cookies and similar tracking technologies to improve the user experience, maintain session security, and collect platform analytics. Cookies are small text files stored on your device when you visit a website. They do not contain executable code and cannot access other files stored on your device.

11.2 Types of Cookies Used by 3jlp

• Essential cookies: Required for the platform to function. These include session authentication cookies that keep you logged in during a gaming session and security cookies that protect against cross-site request forgery. Essential cookies cannot be disabled without preventing normal platform use.
• Analytics cookies: Collect anonymous, aggregated data on how Members use the platform — including pages visited, session duration, and navigation paths. This data is used to identify areas for platform improvement. Analytics cookies do not identify you personally.
• Functional cookies: Remember your platform preferences — including your preferred language, last-visited game category, and responsible gaming settings — so they persist between sessions.
• Security and fraud-prevention cookies: Used to detect suspicious activity, identify devices used across multiple accounts, and support anti-money laundering monitoring obligations.

11.3  Non-essential cookies (analytics and functional) may be declined through your browser settings without affecting your ability to use the platform. Declining security and fraud-prevention cookies, however, may impair 3jlp's ability to protect your account and comply with regulatory obligations, and may result in additional identity verification requirements being applied to your account.

11.4  3jlp does not use third-party advertising cookies or behavioural tracking technologies for commercial advertising purposes on behalf of external advertisers.

12 Minors and Age Verification

12.1  The 3jlp platform is strictly intended for individuals aged 21 years and above. 3jlp does not knowingly collect personal data from individuals under the age of 21. As part of the mandatory KYC process, 3jlp verifies the age of all Members prior to enabling real-money account activity.

12.2  If 3jlp becomes aware — through KYC verification, a complaint, or any other means — that personal data of an individual under 21 years of age has been collected, that data will be immediately deleted, the associated account will be permanently suspended, and any deposits will be returned to the originating payment method.

12.3  If you believe that a minor has registered an account on 3jlp, please contact our support team immediately via live chat or the email address in Section 16. 3jlp treats such reports as urgent and will investigate and act within 24 hours of receipt.

13 Exercising Your Data Privacy Rights

13.1  To exercise any of the data subject rights described in the summary section of this page — including rights to access, rectification, erasure, objection, or portability — you must submit a written request to 3jlp's Data Protection Officer using the contact details provided in Section 16.

13.2  All data subject requests will be acknowledged within five (5) business days of receipt. 3jlp will endeavour to respond substantively within fifteen (15) business days. Complex or high-volume requests may require additional time; in such cases, 3jlp will notify you of the extended timeline and the reasons for the delay.

13.3  3jlp may require identity verification before processing any data subject request to prevent unauthorised access to your personal data by a third party claiming to act on your behalf.

13.4  Where 3jlp declines a data subject request — for example, where fulfilling it would conflict with a legal obligation under RA 9160 — 3jlp will provide a written explanation of the grounds for refusal.

13.5  If you are not satisfied with 3jlp's response to a data subject request, you have the right to escalate your complaint to the National Privacy Commission (NPC) at privacy.gov.ph.

14 Data Breach Notification Protocol

14.1  In the event of a personal data breach that poses a real risk of serious harm to affected data subjects, 3jlp will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required under Section 20(f) of the Data Privacy Act of 2012 and NPC Circular 16-03.

14.2  Where the breach is assessed to affect the rights and freedoms of Members, 3jlp will also notify affected Members without undue delay using their registered mobile number or email address. Notification will include: a description of the nature of the breach, the categories and approximate number of data subjects affected, contact details of the DPO, and the measures taken or proposed to address the breach.

14.3  3jlp maintains an internal data breach register in compliance with NPC requirements. All security incidents are investigated, documented, and remediated as a matter of priority.

15 Amendments to This Privacy Policy

15.1  3jlp reserves the right to update or amend this Privacy Policy at any time. The "Last Updated" date at the top of this page reflects the date of the most recent revision.

15.2  For material amendments — those that substantially change how your personal data is collected or used — 3jlp will provide at least seven (7) days' advance notice via your registered mobile number or email address before the revised policy takes effect.

15.3  Your continued use of the 3jlp platform following the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. If you do not agree to the revised terms, you should cease use of the platform and may request account closure in accordance with the Terms and Conditions.

16 Contact and Data Protection Officer

For all data privacy queries, data subject requests, and concerns about how 3jlp processes your personal information, please contact us through the following channels:

• Data Protection Officer: Contactable via the email address below. All data subject rights requests should be submitted in writing to the DPO with your full name, registered mobile number, and a description of your request.
• Email: [email protected] — Please mark the subject line "DATA PRIVACY REQUEST" to ensure your query is routed directly to the DPO. Average response time is under 4 hours for standard queries; data subject requests are acknowledged within 5 business days.
• Live Chat: Available 24/7 from within your 3jlp account dashboard — recommended for general privacy questions and for urgent matters such as suspected account compromise or requests to suspend data processing immediately.

For complaints about 3jlp's data processing practices that cannot be resolved internally, you may also contact the National Privacy Commission of the Philippines at privacy.gov.ph. 3jlp cooperates fully with NPC investigations.