3jlq Privacy Policy

1. Introduction and Scope

3jlq ("we," "us," "our," or "the Company") is committed to protecting the privacy and personal data of all users of our online gaming platform. This Privacy Policy applies to all personal information collected through the 3jlq website, mobile applications, customer support channels, and related services (collectively, the "Platform").

As a PAGCOR-licensed gaming operator in the Philippines, 3jlq adheres to the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, National Privacy Commission circulars, and other applicable data protection laws. We are also committed to implementing internationally recognized data protection principles to ensure the highest standards of privacy and security for our Filipino players.

By creating a 3jlq account or using our services, you acknowledge that you have read, understood, and consent to the data collection, processing, and usage practices described in this Privacy Policy. If you do not agree with these practices, please do not register for an account or use our Platform.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act and applicable data protection regulations, 3jlq acts as the Data Controller for all personal information collected through the Platform. As Data Controller, we determine the purposes and means of processing your personal data and are responsible for ensuring compliance with applicable privacy laws.

You may also contact the National Privacy Commission of the Philippines if you believe your data protection rights have been violated. The NPC is the primary government agency responsible for administering and implementing the Data Privacy Act in the Philippines.

3. Information We Collect

3.1 Personal Information You Provide

When you register for a 3jlq account, we collect identifying information necessary for account creation, identity verification, and regulatory compliance. This information includes:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (passport number, driver's license number, SSS/GSIS number, TIN, or other official ID numbers).
• Contact Information: Residential address, postal code, email address, and Philippine mobile telephone number.
• Account Credentials: Username, password (stored in encrypted form), security questions and answers, and two-factor authentication settings.
• Financial Information: Bank account details, GCash mobile number, Maya account information, payment card details (processed securely by third-party payment processors who are PCI-DSS compliant), transaction history, deposit sources, and withdrawal destinations.
• Verification Documents: Copies of government-issued identification cards, proof of address documents (utility bills, bank statements), and facial photographs for identity verification purposes.
• Communication Records: Content of customer support inquiries, live chat transcripts, email correspondence, phone call recordings (with your consent), and any other communications you send to us.

3.2 Information Collected Automatically

When you access the 3jlq Platform, we automatically collect certain technical and usage information through cookies, log files, and similar technologies:

• Device Information: IP address, device type and model, operating system and version, browser type and version, screen resolution, device identifiers, and mobile network information.
• Usage Data: Pages visited, games played, betting patterns, deposit and withdrawal history, session duration, click patterns, navigation paths, referral sources, and timestamps of activities.
• Location Data: Geolocation information derived from your IP address to verify that you are accessing the Platform from within the Philippines as required by our PAGCOR license.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, pixel tags, and similar technologies to enhance your user experience, remember your preferences, and analyze Platform performance.

3.3 Information from Third Parties

We may receive information about you from third-party sources including identity verification services, fraud prevention providers, payment processors, credit reference agencies, PAGCOR regulatory databases, and publicly available sources. This information is used to verify your identity, prevent fraud, and ensure compliance with anti-money laundering regulations.

4. How We Use Your Personal Data

3jlq processes your personal information for the following specific purposes, all of which are necessary for providing our gaming services and fulfilling our legal obligations:

4.1 Account Management and Service Provision

• Creating and maintaining your player account
• Authenticating your identity when you log in
• Processing deposits, withdrawals, and other financial transactions
• Enabling you to place bets and participate in games
• Calculating winnings, losses, and account balances
• Administering bonuses, promotions, and loyalty programs
• Providing customer support and responding to your inquiries
• Sending transactional notifications about account activity

4.2 Legal and Regulatory Compliance

• Verifying your age to ensure you are 21 years or older
• Confirming your identity and residential location within the Philippines
• Complying with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Detecting and preventing fraud, money laundering, and terrorist financing
• Reporting suspicious transactions to AMLC as required by law
• Maintaining records for PAGCOR audits and regulatory inspections
• Responding to lawful requests from courts, law enforcement, and regulatory authorities
• Enforcing our Terms and Conditions and investigating violations

4.3 Security and Fraud Prevention

• Monitoring accounts for unusual activity or suspicious behavior
• Detecting unauthorized account access and preventing identity theft
• Identifying multiple accounts, collusion, and bonus abuse
• Protecting against hacking attempts, DDoS attacks, and other security threats
• Investigating disputes, complaints, and Terms violations

4.4 Platform Improvement and Analytics

• Analyzing usage patterns to improve website functionality and user experience
• Testing new features, games, and platform updates
• Conducting statistical analysis of player behavior and preferences
• Optimizing game performance and loading times
• Personalizing content and game recommendations

4.5 Marketing and Communications (With Your Consent)

With your explicit consent, we may use your contact information to send promotional communications about new games, special offers, exclusive bonuses, tournaments, and other marketing materials. You may withdraw consent and opt out of marketing communications at any time through your account settings or by clicking the unsubscribe link in promotional emails.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, we process your personal data based on the following legal grounds:

6. Data Sharing and Disclosure

6.1 When We Share Your Information

3jlq does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with the following categories of recipients when necessary for legitimate business purposes:

• Payment Processors: GCash, Maya, banks, and other payment service providers process your financial transactions and require certain personal and financial information to complete deposits and withdrawals.
• Identity Verification Services: Third-party KYC and AML compliance providers verify your identity, check sanctions lists, and assess fraud risk as required by regulatory obligations.
• Game Providers: Licensed game developers and platform providers receive limited information necessary to deliver gaming content and calculate game outcomes.
• Customer Support Tools: We use third-party software for live chat, ticketing systems, and email management to provide efficient customer support.
• Analytics and Performance Services: Website analytics tools help us understand user behavior and improve Platform performance. These providers collect anonymized or pseudonymized data.
• Regulatory Authorities: We disclose information to PAGCOR, the Anti-Money Laundering Council, National Privacy Commission, and other Philippine government agencies as required by law or regulatory directives.
• Law Enforcement and Courts: We respond to valid legal processes including subpoenas, court orders, and lawful requests from government authorities investigating criminal activity.
• Professional Advisors: Lawyers, accountants, auditors, and other professional consultants may access your information when providing services to 3jlq.
• Corporate Transactions: If 3jlq undergoes a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity subject to the same privacy protections.

6.2 Data Processing Agreements

All third-party service providers who process personal data on behalf of 3jlq are bound by written data processing agreements that require them to implement appropriate technical and organizational security measures, process data only according to our instructions, and comply with applicable data protection laws.

6.3 International Data Transfers

Your personal data is primarily stored and processed within the Philippines. However, some of our service providers (such as cloud hosting providers and software vendors) may store or process data on servers located outside the Philippines. When we transfer data internationally, we ensure appropriate safeguards are in place including standard contractual clauses, adequacy decisions, or other mechanisms approved by the National Privacy Commission.

7. Data Security Measures

3jlq implements comprehensive technical, physical, and organizational security measures to protect your personal information against unauthorized access, loss, destruction, alteration, or disclosure. Our security practices include:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher. Sensitive data at rest (including passwords and financial information) is encrypted using industry-standard algorithms.
• Access Controls: Personal data is accessible only to authorized employees and contractors who need it to perform their job functions. Access is granted on a need-to-know basis and protected by multi-factor authentication.
• Network Security: Firewalls, intrusion detection systems, DDoS protection, and regular security monitoring protect our infrastructure from cyber threats.
• Secure Data Centers: Our servers are hosted in certified data centers with 24/7 physical security, environmental controls, redundant power and cooling systems, and disaster recovery capabilities.
• Regular Security Audits: We conduct periodic security assessments, penetration testing, and vulnerability scans to identify and remediate potential weaknesses.
• Employee Training: All staff members receive mandatory data privacy and security training upon hiring and annually thereafter.
• Incident Response: We maintain a documented incident response plan to quickly detect, contain, and respond to any data breaches or security incidents.

8. Data Retention Periods

3jlq retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods vary based on data type and regulatory requirements:

• Account Information: Retained for the duration of your active account plus six (6) years after account closure to comply with PAGCOR record-keeping requirements and potential legal claims.
• Transaction Records: Retained for ten (10) years as required by Philippine anti-money laundering regulations and tax laws.
• Identity Verification Documents: Retained for six (6) years after account closure or as required by applicable regulations.
• Communication Records: Retained for three (3) years for dispute resolution and quality assurance purposes.
• Marketing Consent Records: Retained until you withdraw consent, plus an additional three (3) years to demonstrate compliance.
• Website Analytics Data: Typically retained in anonymized form for twenty-six (26) months.

After the applicable retention period expires, personal data is securely deleted or anonymized so that it can no longer be associated with you. Anonymized data may be retained indefinitely for statistical and research purposes.

9. Your Data Protection Rights

Under the Philippine Data Privacy Act, you have the following rights regarding your personal data. To exercise these rights, contact our Data Protection Officer at [email protected] with your full name, account username, and specific request:

9.1 Right to Be Informed

You have the right to be informed about the collection and processing of your personal data. This Privacy Policy fulfills that obligation by clearly describing our data practices.

9.2 Right to Access

You may request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format within thirty (30) days of your request. You can also access much of your personal information directly through your account dashboard.

9.3 Right to Rectification

If your personal information is inaccurate, incomplete, or outdated, you have the right to have it corrected. You can update most information directly through your account settings, or contact customer support for assistance.

9.4 Right to Erasure (Right to Be Forgotten)

You may request deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes it was collected, you withdraw consent, or the data was processed unlawfully. However, we may be required to retain certain information to comply with legal obligations or establish legal claims. If erasure is not possible, we will explain the reasons.

9.5 Right to Restrict Processing

You may request that we temporarily restrict processing of your personal data when you contest its accuracy, believe processing is unlawful but don't want erasure, or need the data for legal claims even though we no longer need it.

9.6 Right to Data Portability

You have the right to receive your personal data in a portable format and transmit it to another data controller when technically feasible. This applies to data you provided to us based on consent or contractual necessity that is processed by automated means.

9.7 Right to Object

You have the right to object to processing based on legitimate interests or for direct marketing purposes. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

9.8 Right to Withdraw Consent

Where processing is based on your consent (such as marketing communications), you may withdraw consent at any time. This will not affect the lawfulness of processing prior to withdrawal.

9.9 Right to File a Complaint

If you believe your data protection rights have been violated, you have the right to file a complaint with the National Privacy Commission. However, we encourage you to contact us first so we can attempt to resolve your concern directly.

10. Cookies and Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device by websites you visit. They enable websites to remember your preferences, authenticate your identity, and analyze how you use the site. 3jlq uses cookies and similar technologies (web beacons, pixels, local storage) to enhance your experience and operate the Platform effectively.

10.2 Types of Cookies We Use

• Essential Cookies: Required for basic Platform functionality including authentication, session management, security features, and load balancing. These cookies cannot be disabled without severely impacting site functionality.
• Performance Cookies: Collect anonymous information about how visitors use the Platform, which pages are most popular, and where errors occur. This helps us improve site performance.
• Functionality Cookies: Remember your preferences (language, region, display settings) to provide a personalized experience.
• Analytics Cookies: Help us understand user behavior through aggregated statistics. We use Google Analytics and similar tools configured to respect privacy standards.
• Advertising Cookies: Track your browsing across websites to deliver relevant advertisements (used only on informational pages, not within the gaming platform itself).

10.3 Managing Cookie Preferences

You can control cookie settings through your browser preferences. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies will prevent you from using certain Platform features including logging in and playing games. Instructions for managing cookies in popular browsers can be found in their respective help sections.

11. Children's Privacy and Age Restrictions

The 3jlq Platform is not intended for individuals under 21 years of age. We do not knowingly collect personal information from minors. Our registration process includes age verification mechanisms, and we require all users to confirm they are at least 21 years old.

If we discover that we have inadvertently collected personal data from an individual under 21 years of age, we will immediately delete that information and terminate the associated account. Any funds in such accounts will be forfeited in accordance with our Terms and Conditions and applicable law.

If you are a parent or guardian and believe your child has provided personal information to 3jlq, please contact us immediately at [email protected] so we can take appropriate action.

12. Changes to This Privacy Policy

3jlq reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes that affect how we collect, use, or protect your personal data, we will notify you through one or more of the following methods:

• Email notification to your registered email address
• Prominent notice on the Platform homepage
• In-account notification when you next log in
• Push notification if you have our mobile app installed

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. The "Last Updated" date at the top of this policy indicates when the most recent changes were made. Your continued use of the 3jlq Platform after policy modifications constitutes your acceptance of the updated terms.

If you do not agree with any changes to this Privacy Policy, you must discontinue use of the Platform and may request account closure and data deletion as described in Section 9.

13. Contact Information for Privacy Inquiries

If you have questions, concerns, or requests regarding this Privacy Policy or how 3jlq processes your personal data, please contact us using the following channels:

• Data Protection Officer: [email protected]
• General Privacy Inquiries: [email protected] (Subject: Privacy Inquiry)
• Data Subject Rights Requests: Submit through your account dashboard under "Privacy Settings" or email [email protected] with "Data Rights Request" in the subject line
• 24/7 Live Chat: Available through the Platform for urgent privacy concerns

When contacting us about privacy matters, please include your full name, registered email address, account username, and a detailed description of your inquiry or request. For security purposes, we will verify your identity before processing data subject rights requests.

We aim to respond to all privacy inquiries within fifteen (15) business days. Complex requests may require additional time, but we will keep you informed of progress and expected resolution timelines.