Privacy Policy — 3jla Casino

1. Introduction

1.1 3jla Casino operates the online gaming platform accessible at 3jla.app (the "Platform"). We are committed to protecting the privacy and security of all personal information entrusted to us by our players and visitors.

1.2 This Privacy Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations, as administered by the National Privacy Commission of the Philippines ("NPC").

1.3 This Policy applies to all personal data collected through the 3jla Platform, including data collected during account registration, gameplay, payment transactions, customer support interactions, and use of our website. It applies to all players, visitors, and any other individuals whose personal data is processed by 3jla.

1.4 By accessing the 3jla Platform or creating an account, 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. Personal Data We Collect

2.1 3jla collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include:

2.1 Identity & Contact Information

• Full legal name as it appears on a government-issued ID;
• Date of birth (to verify the 21+ age requirement);
• Email address and mobile phone number;
• Residential address (city, province, postal code);
• Nationality and government-issued ID number (for KYC verification).

2.2 Financial Information

• GCash or PayMaya/Maya account number (mobile number);
• Bank account details (account name, account number, bank name) for withdrawal processing;
• Debit card details (card number, expiry date) where applicable;
• Transaction history, including deposit amounts, withdrawal amounts, and dates.

2.3 Gaming Activity Data

• Game history, bet amounts, win/loss records, and session durations;
• Bonus and promotion usage history;
• Responsible gaming tool settings (deposit limits, self-exclusion status).

2.4 Technical & Device Data

• IP address and approximate geographic location;
• Device type, operating system, and browser type;
• Login timestamps and session activity logs;
• Cookies and similar tracking technology data (see Section 7).

2.5 Communications Data

• Records of customer support interactions (chat logs, email correspondence);
• Feedback, survey responses, and promotional opt-in preferences.

3. How We Collect Your Data

3jla collects personal data through the following means:

• Account Registration: Information you provide when creating your 3jla account, including name, email, date of birth, and contact details;
• KYC Verification: Identity documents and supporting materials submitted during the verification process;
• Payment Transactions: Financial details provided when making deposits or requesting withdrawals;
• Platform Usage: Data automatically generated as you navigate and interact with the 3jla Platform, including gameplay data and session logs;
• Customer Support: Information you share when contacting our support team via live chat or email;
• Cookies & Analytics: Technical data collected automatically through cookies and similar technologies as described in Section 7;
• Third-Party Sources: In limited circumstances, we may receive data from payment processors, identity verification providers, or fraud prevention services to supplement the information you have provided.

4. How We Use Your Personal Data

4.1 3jla uses the personal data we collect for the following purposes:

4.2 3jla will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

5. Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you agreed to when registering your 3jla account, including account management, payment processing, and game provision;
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including KYC requirements, AML obligations, and PAGCOR regulatory requirements;
• Legitimate Interests: Processing is necessary for 3jla's legitimate interests in fraud prevention, platform security, and service improvement, provided such interests are not overridden by your rights and freedoms;
• Consent: For marketing communications and non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

6.1 3jla does not sell, rent, or trade your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya/Maya, and banking partners require certain financial and identity data to process your transactions securely;
• Identity Verification Providers: Third-party KYC service providers who assist in verifying your identity and age in compliance with regulatory requirements;
• Fraud Prevention & Security Services: Providers who help us detect and prevent fraudulent activity, money laundering, and unauthorized account access;
• Game Software Providers: Licensed game studios and live dealer platform providers who supply the games available on 3jla may receive limited gameplay data necessary to operate their services;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies as required by law;
• IT & Hosting Providers: Cloud infrastructure and hosting partners who store and process data on our behalf under strict data processing agreements;
• Professional Advisors: Legal counsel, auditors, and compliance consultants where necessary for the operation of our business.

6.2 All third parties with whom 3jla shares personal data are required to handle such data in accordance with applicable Philippine privacy laws and are prohibited from using your data for their own independent purposes.

6.3 In the event of a merger, acquisition, or sale of all or substantially all of 3jla's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. We will notify you of any such transfer via the contact information on file.

7. Cookies & Tracking Technologies

7.1 The 3jla Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze how the Platform is used. A cookie is a small text file placed on your device when you visit a website.

7.2 3jla uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session authentication and security tokens. These cannot be disabled without affecting core functionality;
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations;
• Analytics Cookies: Help us understand how players interact with the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible;
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and activity on the Platform. These are only activated with your explicit consent.

7.3 You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 3jla Platform. Refer to your browser's help documentation for instructions on managing cookie preferences.

8. Data Retention

8.1 3jla retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations.

8.2 The following general retention periods apply:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with AML and PAGCOR record-keeping requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under Philippine AML regulations;
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship;
• Customer Support Records: Retained for three (3) years from the date of the last interaction;
• Marketing Preferences: Retained until you withdraw consent or request deletion, whichever is earlier.

8.3 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 3jla's data disposal procedures.

9. Data Security

9.1 3jla implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 3jla Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting data access to authorized personnel only;
• Regular security assessments, vulnerability testing, and system audits;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Staff training on data privacy obligations and security best practices.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 3jla will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with the DPA.

9.3 While 3jla takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorized access to your account.

10. Your Rights as a Data Subject

10.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 3jla:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed, as described in this Policy;
• Right of Access: You may request a copy of the personal data 3jla holds about you, along with information about how it is being processed;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you;
• 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 our legal retention obligations;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes 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, and 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 privacy rights have been violated.

10.2 To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 13. We will respond to all valid requests within fifteen (15) business days. We may require you to verify your identity before processing your request.

11. Children's Privacy

11.1 The 3jla Platform is strictly intended for individuals who are twenty-one (21) years of age or older, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

11.2 If 3jla becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete such data and close the associated account. If you believe a minor has registered on the 3jla Platform, please contact us immediately at the details provided in Section 13.

12. Changes to This Privacy Policy

12.1 3jla reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. The updated Policy will be posted on this page with a revised "Last updated" date.

12.2 Where changes are material, we will notify registered players via the email address on file or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the 3jla Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms.

12.3 We encourage you to review this Privacy Policy periodically to stay informed about how 3jla protects your personal data.

13. Contact & Data Protection Officer

13.1 3jla has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy.

13.2 If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our DPO:

13.3 If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about how to file a complaint is available on the NPC's official website.