Privacy Policy — 37jl9

1. Introduction

This Privacy Policy ("Policy") describes how 37jl9 ("37jl9," "we," "us," or "our") collects, uses, discloses, and safeguards personal information obtained from users ("you" or "Player") of the 37jl9 online gaming platform accessible at https://37jl9.net and all associated services (collectively, the "Platform").

37jl9 is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. This Policy is designed to comply with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

By registering an account, accessing the Platform, or otherwise providing your personal information to 37jl9, 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. If you do not agree with this Policy, please discontinue use of the Platform immediately.

2. Information We Collect

37jl9 collects personal information that is necessary to provide you with a safe, secure, and personalized gaming experience. The categories of information we collect include:

2.1 Registration Information. When you create a 37jl9 account, we collect your full name, date of birth, email address, mobile number, and residential address. This information is required to verify your identity and ensure compliance with the 21+ age requirement under Philippine gaming regulations.

2.2 Identity Verification Documents. To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, 37jl9 may request copies of government-issued Philippine identification documents (such as a PhilSys ID, passport, driver's license, or SSS/GSIS card), proof of address, and proof of payment method ownership.

2.3 Financial Information. We collect information related to your deposits and withdrawals, including transaction amounts, payment method types (GCash, PayMaya, BPI, BDO, Metrobank), and transaction reference numbers. We do not store full bank account numbers or complete GCash/PayMaya credentials.

2.4 Gaming Activity Data. We collect records of your gaming sessions, including games played, wagers placed, wins and losses, bonus usage, and session duration. This data is used for account management, responsible gaming monitoring, and regulatory compliance.

2.5 Technical and Device Data. When you access the Platform, we automatically collect technical information including your IP address, browser type and version, operating system, device identifiers, and referring URLs. This data helps us maintain platform security and optimize your experience.

2.6 Communications Data. If you contact 37jl9 customer support, we retain records of your communications, including emails, chat transcripts, and support tickets, to assist with ongoing inquiries and improve our service quality.

3. How We Use Your Information

37jl9 uses the personal information we collect for the following purposes:

• To create, verify, and manage your 37jl9 player account;
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP);
• To verify your identity and age (21+) in compliance with Philippine gaming regulations;
• To detect, prevent, and investigate fraud, money laundering, and other prohibited activities;
• To provide customer support and respond to your inquiries;
• To send you account-related notifications, transaction confirmations, and security alerts;
• To personalize your gaming experience and deliver relevant promotions and bonuses;
• To monitor gaming activity for responsible gaming purposes and enforce self-exclusion requests;
• To analyze platform usage and improve our services, games, and features;
• To comply with applicable Philippine laws, regulations, and regulatory requirements.

37jl9 will not use your personal information for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 37jl9 processes your personal information on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management and transaction processing.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, KYC requirements, and gaming regulatory obligations.
• Legitimate Interests: Processing is necessary for 37jl9's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities, such as marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

5. Sharing of Personal Information

37jl9 does not sell, rent, or trade your personal information to third parties. We may share your information only in the following limited circumstances:

• Service Providers: We share data with trusted third-party service providers who assist us in operating the Platform, including payment processors, identity verification services, IT infrastructure providers, and customer support platforms. These providers are contractually bound to process your data only as instructed by 37jl9 and in accordance with applicable data protection laws.
• Regulatory Authorities: We may disclose personal information to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other Philippine government authorities when required by law or in response to a valid legal request.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of 37jl9's business, your personal information may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.
• With Your Consent: We may share your information with third parties for purposes not described in this Policy if you have given your explicit prior consent.

6. Cookies and Tracking Technologies

37jl9 uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

We use the following types of cookies:

• Essential Cookies: Required for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and display options to provide a more personalized experience.
• Analytics Cookies: Help us understand how players interact with the Platform so we can improve performance and usability.
• Marketing Cookies: Used to deliver relevant promotions and measure the effectiveness of our marketing campaigns. These are only set with your consent.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

7. Data Retention

37jl9 retains your personal information for as long as your account remains active and for a period thereafter as required by applicable Philippine law and regulatory obligations. Specifically:

• Account and identity verification data is retained for a minimum of five (5) years following account closure, in compliance with AML regulations.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the last interaction.
• Marketing consent records are retained until you withdraw your consent or for three (3) years from the date of consent, whichever is earlier.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, 37jl9 will securely delete or anonymize the data.

8. Data Security

37jl9 implements appropriate technical and organizational security measures to protect your personal information against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 37jl9 Platform;
• Encrypted storage of sensitive personal and financial data;
• Access controls limiting data access to authorized personnel only;
• Regular security assessments and vulnerability testing;
• Staff training on data protection and information security practices.

While 37jl9 takes all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that poses a risk to your rights and freedoms, 37jl9 will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

9. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal information held by 37jl9:

• Right to be Informed: You have the right to know how your personal data is being collected and processed.
• Right of Access: You may request a copy of the personal information 37jl9 holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing or where processing is based on legitimate interests.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 12 of this Policy. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

10. Children's Privacy

The 37jl9 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. We do not knowingly collect personal information from anyone under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that information and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately at [email protected].

11. Changes to This Privacy Policy

37jl9 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered players via email or an in-platform notification. Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we protect your information.

12. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact the 37jl9 Data Protection Officer:

• Email: [email protected]
• Support Hours: Daily, 8:00 AM – 12:00 MN (Philippine Standard Time)
• Service Area: Manila, Cebu, Davao, Quezon City, Makati, and all regions of the Philippines

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.