636jl Privacy Policy

1. Introduction

636jl ("636jl," "we," "us," or "our") operates the online gaming platform accessible at 636jl.app and is committed to protecting the privacy and personal data of all users ("Player," "User," or "you"). This Privacy Policy describes how 636jl collects, uses, stores, shares, and protects your personal information in connection with your use of the 636jl platform and all related services.

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 administered by the National Privacy Commission (NPC) of the Philippines. By registering for a 636jl account or using any part of the 636jl platform, 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.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Personal Data We Collect

636jl collects personal data from you in the following categories, depending on how you interact with our platform:

2.1 Registration and Identity Data

When you create a 636jl account, we collect: your full legal name, date of birth, nationality, Philippine mobile number, email address, and username. This information is required to create and maintain your account and to verify your eligibility to use the platform.

2.2 Identity Verification (KYC) Data

To comply with anti-money laundering (AML) regulations and PAGCOR requirements, 636jl may collect copies of government-issued identification documents (such as a PhilSys National ID, passport, driver's license, SSS/GSIS card, or PRC ID), proof of address documents, and selfie photographs for facial verification purposes. KYC data is collected prior to processing your first withdrawal.

2.3 Financial Data

636jl collects information necessary to process deposits and withdrawals, including your GCash or PayMaya mobile number, bank account details (account name, account number, bank name), and debit card details where applicable. 636jl does not store full card numbers — payment data is tokenized and handled by our PCI-DSS compliant payment processors.

2.4 Transaction and Gaming Data

We maintain records of all transactions conducted through your 636jl account, including deposits, withdrawals, bonus credits, wagers placed, games played, game outcomes, and account balance history. This data is required for regulatory compliance, dispute resolution, and responsible gaming monitoring.

2.5 Technical and Device Data

When you access 636jl, we automatically collect certain technical data, including your IP address, device type and model, operating system, browser type and version, screen resolution, time zone, and session duration. This data is used for security monitoring, fraud prevention, and platform optimization.

2.6 Communications Data

If you contact 636jl's customer support team via live chat, email, or any other channel, we retain records of those communications, including the content of messages and any attachments, for quality assurance, training, and dispute resolution purposes.

Data Category	Examples	Required?
Registration Data	Name, email, mobile number, date of birth	Required
KYC / Identity	Government ID, proof of address, selfie	For withdrawals
Financial Data	GCash number, bank account, debit card	For transactions
Gaming & Transaction	Bets, game history, deposits, withdrawals	Required
Technical / Device	IP address, browser, device type	Auto-collected
Communications	Support chat logs, emails	When contacted

3. How We Use Your Personal Data

636jl uses the personal data we collect for the following specific purposes:

• Account Management: To create, maintain, and administer your 636jl account, including processing your registration, verifying your identity, and managing your account settings and preferences.
• Payment Processing: To process deposits and withdrawals through your chosen payment method (GCash, PayMaya, bank transfer, or debit card), and to maintain accurate financial records of all transactions on your account.
• Regulatory Compliance: To fulfill our obligations under Philippine law, including PAGCOR licensing requirements, anti-money laundering (AML) regulations, and the Data Privacy Act of 2012. This includes conducting KYC verification and filing mandatory reports with relevant authorities where required.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, bonus abuse, and other prohibited conduct on the 636jl platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, to enforce deposit and loss limits set by players, and to administer self-exclusion requests in accordance with our Responsible Gaming Policy.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our live chat and email support channels.
• Platform Improvement: To analyze aggregated, anonymized usage data to improve the performance, features, and user experience of the 636jl platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates via email or SMS, where you have provided your consent to receive such communications. You may opt out at any time.
• Legal Proceedings: To establish, exercise, or defend legal claims in the event of a dispute between you and 636jl.

636jl will not use your personal data 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, 636jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your 636jl account, process transactions, and deliver the gaming services you have requested.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AML obligations, and tax reporting requirements.
• Legitimate Interests: Processing is necessary for 636jl's legitimate interests in preventing fraud, ensuring platform security, and improving our services, provided those interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — we rely on your freely given, specific, and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5. Sharing Your Personal Data

636jl does not sell, rent, or trade your personal information to any third party. We may share your data only in the following limited circumstances:

5.1 Service Providers. We share data with carefully selected third-party service providers who assist us in operating the 636jl platform, including payment processors (e.g., GCash, Maya, banking partners), KYC and identity verification providers, cloud hosting and infrastructure providers, customer support software providers, and fraud detection and cybersecurity services. All service providers are bound by data processing agreements that require them to handle your data securely and only for the purposes we specify.

5.2 Game Software Providers. The games available on 636jl are powered by licensed third-party game studios. These providers may receive limited technical data (such as a pseudonymous player ID and game session data) necessary to deliver the game experience. They do not receive your full personal profile.

5.3 Regulatory and Law Enforcement Authorities. 636jl may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government authorities where required by law, court order, or regulatory directive.

5.4 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of 636jl's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer via the email address on your account.

5.5 With Your Consent. We may share your data with other third parties where you have given your explicit consent for us to do so.

6. Cookies and Tracking Technologies

636jl uses cookies and similar technologies (such as local storage and session tokens) to operate and improve the platform. Here is a breakdown of the types of cookies we use:

Cookie Type	Purpose	Can Be Disabled?
Essential Cookies	Keep you logged in, maintain your session, and enable core platform functionality. Without these, the platform cannot function.	No
Preference Cookies	Remember your language, display settings, and other platform preferences so you don't have to reset them each visit.	Optional
Analytics Cookies	Collect anonymized data about how players use the platform to help us identify performance issues and improve the user experience.	Optional
Security Cookies	Help detect and prevent fraudulent activity, unauthorized logins, and bot traffic on the platform.	No

636jl does not use third-party advertising or tracking cookies. You can manage or delete cookies through your browser settings at any time. Please note that disabling essential or security cookies may affect your ability to use the 636jl platform.

7. Data Security

636jl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and 636jl's servers is encrypted using industry-standard TLS protocols.
• Password Hashing: Account passwords are never stored in plain text. They are hashed using a strong one-way cryptographic algorithm before storage.
• Access Controls: Access to personal data within 636jl's systems is restricted on a strict need-to-know basis. Staff members are granted only the minimum level of access required to perform their job functions.
• Two-Factor Authentication (2FA): 636jl offers optional 2FA for player accounts to provide an additional layer of login security.
• Regular Security Audits: 636jl conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities in our systems.
• Incident Response: In the event of a personal data breach that poses a risk to your rights and freedoms, 636jl will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, as required by the DPA.

While 636jl takes all reasonable steps to protect your data, no system is completely immune to security risks. You are responsible for keeping your 636jl login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

8. Data Retention

636jl 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 and regulatory obligations. The following general retention periods apply:

• Account and Registration Data: Retained for the duration of your active account, plus a minimum of five (5) years following account closure, as required by PAGCOR and AML regulations.
• KYC and Identity Verification Data: Retained for a minimum of five (5) years following account closure or the completion of the last transaction, in accordance with AML obligations.
• Transaction and Gaming Records: Retained for a minimum of five (5) years following the date of each transaction, as required by Philippine financial regulations.
• Customer Support Communications: Retained for up to three (3) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Technical and Device Data: Retained for up to twelve (12) months from the date of collection, unless required for longer periods for security investigations.
• Marketing Consent Records: Retained for the duration of your consent, plus a reasonable period thereafter to demonstrate compliance.

When personal data is no longer required, 636jl will securely delete or anonymize it in accordance with our internal data disposal procedures. Anonymized data (which can no longer identify you) may be retained indefinitely for statistical and analytical purposes.

9. Your Privacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 636jl:

• Right to Be Informed: You have the right to be informed about how your personal data is being collected and processed. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data that 636jl holds about you, along with information about how it is being used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most account information directly through your 636jl account settings.
• Right to Erasure: You have 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: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our overriding legal obligations.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to Lodge a Complaint: If you believe that 636jl has violated your privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact 636jl's Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days of receipt. We may need to verify your identity before processing your request.

10. Children's Privacy and Age Restriction

The 636jl platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law governing casino-style gambling. 636jl does not knowingly collect personal data from individuals under the age of 21.

If you are under 21 years of age, you are not permitted to register for or use the 636jl platform. If 636jl becomes aware that personal data has been collected from a person under 21, we will immediately close the associated account, delete the data, and refund any deposits made, with any winnings forfeited.

If you are a parent or guardian and believe that your child has registered on 636jl, please contact us immediately at [email protected] so that we can take prompt action.

11. Changes to This Privacy Policy

636jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via the email address on file and/or by displaying a prominent notice on the 636jl platform prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data. Your continued use of the 636jl platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 636jl handles your personal data, please contact our Data Protection Officer using the details below:

You also have the right to escalate unresolved privacy concerns to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.