Privacy Policy

1. Who We Are

368jl (referred to in this Privacy Policy as "368jl", "we", "us", or "our") operates the online gaming and sports betting platform accessible at https://368jl.app (the "Platform"). 368jl acts as the personal information controller in respect of the personal data of all registered account holders and Platform visitors.

368jl operates within the regulatory framework of Philippine gaming law and is subject to the data privacy obligations imposed by Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations issued by the National Privacy Commission ("NPC") of the Philippines.

This Privacy Policy governs how 368jl processes personal information in connection with account registration, the use of gaming services, payment transactions, customer support interactions, and any other activity conducted through the Platform.

2. Scope of This Policy

This Privacy Policy applies to all individuals who:

• Register or apply to register a 368jl account;
• Access or browse the 368jl Platform as a visitor, whether or not they hold a registered account;
• Contact 368jl customer support through any channel;
• Participate in any 368jl promotion, survey, or loyalty program;
• Submit any personal information to 368jl through any means.

This policy does not apply to the privacy practices of third-party websites, payment providers, or service partners that 368jl may work with. We encourage you to review the privacy policies of any third-party services you interact with independently of the 368jl Platform.

3. Personal Data We Collect

368jl collects the following categories of personal information from players and Platform visitors:

3.1 Registration and Identity Data

When you create a 368jl account, we collect your full legal name, date of birth, gender, nationality, Philippine mobile number, and the username you select. Where GCash or Maya verification is used during registration, we receive confirmation of your identity and linked mobile number from the relevant payment provider in accordance with their own terms.

3.2 Know Your Customer (KYC) and Verification Data

In compliance with Philippine anti-money laundering obligations and PAGCOR regulatory requirements, 368jl collects government-issued identification documents (such as passport, SSS/UMID card, PhilSys National ID, driver's license, PRC ID, or voter's ID), proof of address documents, and photographs or video verification where required. This data is used exclusively for identity verification and compliance purposes.

3.3 Financial and Transaction Data

368jl collects records of all deposits, withdrawals, bonuses credited and redeemed, wagers placed, and game session outcomes associated with your account. We also collect the identity of your payment method (GCash number, Maya account, or bank account details) to the extent necessary to process transactions. 368jl does not store full credit or debit card numbers on its own systems.

3.4 Technical and Device Data

When you access the Platform, we automatically collect technical data including your IP address, browser type and version, operating system, device type and identifiers, time zone setting, language preference, and access timestamps. This data is used for security monitoring, fraud prevention, and platform optimisation.

3.5 Usage and Behavioural Data

We collect data about how you interact with the 368jl Platform, including pages viewed, games played, session duration, clickstream data, search queries on the Platform, and the sequence of actions taken during a session. This data helps us improve the Platform experience and personalise content where applicable.

3.6 Communications Data

If you contact 368jl customer support via live chat, email, or any other channel, we retain records of those communications including the subject matter, content, and any resolutions provided. This data is used for quality assurance, dispute resolution, and staff training.

3.7 Marketing and Preference Data

Where you have provided consent, we collect your marketing preferences and track your responses to promotional communications — such as whether you opened a notification or clicked a link — to improve the relevance and targeting of future communications.

4. How We Collect Your Data

368jl collects personal data through the following means:

• Directly from you — when you register an account, complete KYC, make a deposit or withdrawal request, contact support, or respond to a promotion;
• Automatically — through cookies, tracking technologies, server logs, and analytics tools when you access the Platform;
• From payment providers — when you link a GCash or Maya account, or process a bank transfer, limited identity and transaction confirmation data is received from your payment provider;
• From identity verification services — where 368jl engages third-party identity verification providers to assist with KYC compliance, those providers may supply verified identity data;
• From regulatory authorities — 368jl may receive information about players from PAGCOR or other relevant regulatory bodies where required for compliance purposes.

5. Purposes of Data Processing

368jl processes your personal data for the following purposes. Where processing is not based on a legal obligation, the specific legal basis is identified in Section 6.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules, 368jl relies on the following legal bases for processing your personal information:

• Performance of a contract: Processing necessary to operate your 368jl account, provide gaming services, and process financial transactions;
• Compliance with a legal obligation: Processing required under Philippine anti-money laundering law (Republic Act No. 9160, as amended), PAGCOR regulatory requirements, and applicable tax law;
• Legitimate interests: Processing necessary for fraud prevention, platform security, customer service, responsible gaming monitoring, and business analytics, where such interests are not overridden by your rights and interests;
• Consent: Processing for direct marketing communications and non-essential cookies, where your specific, informed, and freely given consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing and Disclosure of Your Data

7.1 Third-Party Service Providers

368jl shares personal data with carefully selected third-party service providers who process data on our behalf and under our instruction. These include payment processors (GCash, Maya, BPI, BDO, Metrobank, and other approved providers), identity verification services, cloud infrastructure providers, fraud detection systems, game software providers, and customer support tools. All third-party processors are contractually bound to process your data only as directed by 368jl and to implement appropriate security measures.

7.2 Regulatory and Law Enforcement Authorities

368jl may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, courts, or other government authorities where required by applicable Philippine law, court order, or regulatory instruction. 368jl will, where legally permissible, notify you of any such disclosure.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of 368jl or its assets, your personal data may be transferred as part of that transaction. You will be notified in advance of any such transfer and of any material change to the processing of your data that may result.

7.4 What We Do Not Do

368jl does not sell, rent, or license your personal information to third-party advertisers, data brokers, or marketing networks. We do not share your data with any party for their own independent marketing purposes without your explicit consent.

8. Cookies and Tracking Technologies

8.1 What We Use

The 368jl Platform uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage) to enable core Platform functionality, remember your session and preferences, detect fraudulent activity, and collect analytics data to improve the Platform.

8.2 Categories of Cookies

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled as they are required to maintain your login session, process transactions, and provide basic security. No consent is required for these cookies.
• Functional cookies: Remember your preferences such as language settings and chosen display options. These improve your experience but are not essential to core Platform operation.
• Analytics cookies: Collect aggregated, anonymised data about how the Platform is used — including which pages are visited most and how players navigate between sections. This data helps 368jl improve the Platform.
• Marketing cookies: Used only where you have given explicit consent, to personalise promotional content and track responses to marketing communications.

8.3 Managing Cookies

You may manage non-essential cookies through your browser settings at any time. Disabling strictly necessary cookies will affect your ability to use certain features of the 368jl Platform, including maintaining a login session. Please refer to your browser's help documentation for instructions on managing cookies.

9. Data Security

368jl implements a layered security framework to protect your personal data from unauthorised access, disclosure, alteration, and destruction. Our security measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and 368jl servers;
• Encryption of sensitive data fields stored in our databases, including payment credentials and identity document references;
• Role-based access controls ensuring that only authorised personnel with a legitimate need can access personal data;
• Multi-factor authentication requirements for all administrative access to data systems;
• Regular penetration testing and vulnerability assessments conducted by independent security professionals;
• Intrusion detection and real-time security monitoring systems;
• Secure data deletion protocols applied when data reaches the end of its retention period.

While 368jl employs all reasonable measures to protect your personal data, no internet transmission or electronic storage method is 100% secure. You play a role in your own data security — please maintain the confidentiality of your 368jl login credentials and notify us immediately if you suspect any unauthorised access to your account.

10. Data Retention

368jl retains your personal data for no longer than is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Active account data: Retained throughout the lifetime of your 368jl account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements;
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of account closure or from the date of the last relevant transaction, as required by the Anti-Money Laundering Act;
• Transaction and financial records: Retained for a minimum of five (5) years following the transaction date, or longer where required by tax or regulatory obligations;
• Customer support communications: Retained for three (3) years following the resolution of the relevant interaction, unless the subject matter forms part of an ongoing legal or regulatory proceeding;
• Marketing and preference data: Retained until you withdraw consent or request deletion, subject to the minimum periods above;
• Technical and usage logs: Retained for a maximum of twelve (12) months unless required longer for security investigation purposes.

Upon expiry of the applicable retention period, your data will be securely deleted or anonymised in a manner that prevents re-identification.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules, you have the following rights with respect to personal information held by 368jl:

11.1 Right to be Informed

You have the right to be informed about how 368jl collects and uses your personal data. This Privacy Policy fulfils that obligation. You may also contact our Data Protection Officer for further details.

11.2 Right to Access

You have the right to request a copy of the personal information 368jl holds about you, together with details of how it is being processed. We will respond to verified access requests within 15 business days.

11.3 Right to Rectification

If any personal data held by 368jl is inaccurate or incomplete, you have the right to request correction. You may update basic account information directly through Account Settings, or contact support for corrections to KYC data.

11.4 Right to Erasure

You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to 368jl's legal obligations to retain certain data — particularly KYC and transaction records — for the minimum periods required by Philippine law.

11.5 Right to Object

You have the right to object to the processing of your personal data where processing is based on legitimate interests, including any use of your data for direct marketing purposes.

11.6 Right to Data Portability

Where technically feasible and where processing is based on your consent or contract performance, you may request that 368jl provide a copy of your personal data in a structured, commonly used, machine-readable format.

11.7 Right to Lodge a Complaint

If you believe 368jl has not complied with the Data Privacy Act of 2012 in the handling of your personal information, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

12. Children's Privacy and Age Restriction

The 368jl Platform is strictly intended for adults aged 21 years and older in compliance with PAGCOR regulations. 368jl does not knowingly collect personal information from individuals under 21 years of age.

If 368jl becomes aware that personal data has been collected from a person below the minimum age requirement, that account will be immediately suspended, the data will be deleted, and any associated funds will be handled in accordance with our Terms and Conditions and applicable law.

If you are a parent or guardian and believe that a minor in your household has registered with 368jl, please contact our support team immediately so that we can investigate and take appropriate action.

13. International Data Transfers

Some of the third-party service providers engaged by 368jl — including cloud infrastructure providers and game content providers — may process personal data outside of the Philippines. Where such transfers occur, 368jl ensures that appropriate safeguards are in place to protect your personal data in accordance with the requirements of the Data Privacy Act of 2012, including the use of contractual data protection clauses that impose obligations on the recipient equivalent to those applicable in the Philippines.

368jl does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate transfer mechanisms and obtaining any required regulatory approvals.

14. Third-Party Links and Services

The 368jl Platform may reference third-party payment services (such as GCash and Maya) and game providers whose own privacy practices are separate from those of 368jl. This Privacy Policy does not govern the data practices of those third parties. We encourage you to review the privacy policies of any third-party services you use in connection with the 368jl Platform.

368jl is not responsible for the privacy practices or the content of any third-party websites, applications, or services that you access in connection with the Platform.

15. Amendments to This Privacy Policy

368jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or updates to the Platform. Where changes are material, we will provide notice to registered players via the Platform or by email to your registered address before the changes take effect.

The effective date of the current version of this Privacy Policy is stated at the top of this document. Your continued use of the 368jl Platform following notification of any amendment constitutes acceptance of the revised policy.

We recommend reviewing this Privacy Policy periodically to stay informed about how 368jl handles your personal data.

16. Contact & Data Protection Officer

368jl has appointed a Data Protection Officer (DPO) as required by the Data Privacy Act of 2012 and the Implementing Rules of the National Privacy Commission. If you have any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data, please contact us through the following channels:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.