Privacy Policy

936jl ("we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the 936jl platform. This Privacy Policy describes how 936jl collects, uses, stores, shares, and protects your personal information when you access or use our website at https://936jl.app and all related services (collectively, the "Platform").

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission of the Philippines. It applies to all personal data we process about registered players, visitors, and any other individuals who interact with the 936jl Platform.

By registering an account on 936jl or by continuing to use the Platform, you acknowledge that you have read this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this policy, please discontinue your use of the Platform and contact our support team to request account closure.

This Privacy Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, which together form the complete agreement governing your use of the 936jl Platform.

936jl collects the following categories of personal data from players and Platform users:

936jl collects your personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies. See Section 7 for more details on cookies.
• Third-Party Sources: Identity and verification data received from KYC service providers, payment processors (such as GCash, Maya, and partner banks), and fraud prevention services when you initiate financial transactions on the Platform.
• Publicly Available Sources: In limited circumstances, 936jl may supplement your profile with information from publicly available sources for fraud prevention and compliance purposes.

936jl uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 936jl player account, including processing your registration, verifying your identity, and managing your account settings.
• Transaction Processing: To process deposits, withdrawals, and other financial transactions on the Platform, and to maintain accurate records of all transactions associated with your account.
• Legal Compliance: To comply with our obligations under Philippine law, including the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, PAGCOR licensing requirements, and other applicable regulations. This includes reporting suspicious transactions to the Anti-Money Laundering Council (AMLC) where required.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal or prohibited conduct on the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our support channels.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, to apply responsible gaming tools you have requested (such as deposit limits or self-exclusion), and to comply with responsible gaming obligations.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the 936jl Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and updates about 936jl — but only where you have given your consent to receive such communications. You may opt out at any time.

Under the Philippine Data Privacy Act of 2012, 936jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you — i.e., to operate your 936jl account, process transactions, and deliver the services you have registered for.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including AMLA reporting obligations, PAGCOR licensing requirements, and tax obligations.
• Legitimate Interests: Processing necessary for 936jl's legitimate business interests, including fraud prevention, platform security, and improving our services — provided these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

936jl does not sell your personal data. We may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Processors: GCash, PayMaya / Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services used to verify your identity and comply with our KYC obligations.
• Game Providers: Licensed third-party game studios and software providers whose games are available on the 936jl Platform, to the extent necessary to deliver game services.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory obligation.
• Fraud Prevention Services: Third-party fraud detection and prevention service providers used to protect the integrity of the Platform and its players.
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on our behalf under strict data processing agreements.

936jl uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session, and analyze usage patterns. The following types of cookies are used:

• Essential Cookies: Strictly necessary for the Platform to function. These cookies enable core features such as account login, session management, and security. They cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform — such as pages visited, time spent, and navigation paths — to help us improve the Platform's performance and user experience.
• Preference Cookies: Used to remember your settings and preferences, such as language selection and display options, so you don't have to re-enter them on each visit.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 936jl Platform. For more information on managing cookies, refer to your browser's help documentation.

936jl 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. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory authority.
• Support Communications: Retained for up to three (3) years from the date of the last communication, unless a longer period is required for dispute resolution or legal proceedings.
• Technical & Log Data: Retained for up to twelve (12) months, unless required for longer periods for security investigations or legal compliance.

When personal data is no longer required, 936jl will securely delete or anonymize it in accordance with our data disposal procedures.

936jl implements a comprehensive set of technical and organizational security measures 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 256-bit SSL/TLS protocols. Sensitive data stored in our systems is encrypted at rest.
• Access Controls: Strict role-based access controls ensure that only authorized 936jl personnel with a legitimate business need can access personal data. All access is logged and audited.
• Firewalls & Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls and intrusion detection systems that monitor for and respond to suspicious activity in real time.
• Regular Security Audits: 936jl conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in our systems.
• Staff Training: All 936jl personnel who handle personal data receive regular training on data privacy obligations and security best practices.

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: The right to be informed about how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data 936jl holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, 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, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated. Visit www.privacy.gov.ph for more information.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14. We will respond to all verified requests within thirty (30) days, as required by the Data Privacy Act.

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

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, delete the personal data, and take appropriate action in accordance with our Terms & Conditions and applicable law.

The 936jl Platform may contain references to third-party services such as payment providers. Please note that 936jl has no control over the privacy practices of third-party services and is not responsible for their privacy policies or data handling practices.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the 936jl Platform, particularly payment providers such as GCash and Maya, whose own privacy policies govern the data you share with them directly.

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. When material changes are made, we will notify registered players via email or by displaying a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when this Privacy Policy was most recently revised. Your continued use of the 936jl Platform following the effective date of any updated Privacy Policy 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 regarding this Privacy Policy or the processing of your personal data by 936jl, please contact our Data Protection Officer (DPO):

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 been violated. The NPC can be reached at www.privacy.gov.ph.