35jl Privacy Policy

This Privacy Policy ("Policy") is issued by 35jl ("35jl," "we," "us," "our"), the operator of the online gaming platform accessible at 35jl.vip and its associated subdomains and services (collectively, the "Platform"). This Policy governs the collection, use, storage, disclosure, and disposal of personal data relating to individuals ("you," "your," "the Player," "data subject") who interact with the Platform in any capacity.

35jl is committed to protecting the privacy and security of your personal information in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and applicable issuances of the National Privacy Commission (NPC) of the Philippines.

By registering an account, accessing the Platform, or engaging with any 35jl service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy is incorporated by reference into the 35jl Terms and Conditions.

35jl collects personal data through multiple touchpoints. The categories and specific data points collected depend on how you interact with the Platform.

2.1 Account Registration Data

When you create a 35jl account, we collect:

• Full legal name (as shown on government-issued ID);
• Date of birth (for age verification — you must be 21+);
• Philippine mobile number;
• Email address;
• Username and encrypted password.

2.2 Identity Verification (KYC) Data

Prior to processing your first withdrawal, 35jl is required to verify your identity. This involves collection of:

• Copy of a valid Philippine government-issued photo ID (passport, driver's license, PhilSys National ID, SSS ID, UMID, or Voter's ID);
• Proof of payment method ownership (where required);
• Selfie or liveness check image for identity matching purposes.

2.3 Financial Transaction Data

Every deposit and withdrawal generates a transaction record that includes payment method identifier (e.g., GCash mobile number, bank account number), transaction amount, currency, timestamp, and transaction reference number. 35jl does not store full payment card numbers. Financial data is retained for the periods required by Philippine anti-money laundering regulations.

2.4 Gameplay and Platform Activity Data

The Platform automatically records game session data including games played, bets placed, outcomes, session durations, and timestamps. This data is used for account statement generation, dispute resolution, and responsible gaming monitoring.

2.5 Technical and Device Data

When you access the Platform, our servers automatically collect technical data including IP address, device type and model, operating system and version, browser type and version, screen resolution, and session identifiers. This data is used for security, fraud detection, and platform performance optimisation.

2.6 Communications Data

When you contact 35jl support via live chat or email, the content of those communications is recorded for quality assurance, training, and dispute resolution purposes. Support interaction records are retained for a minimum of two (2) years.

2.7 Marketing Preference Data

Where you have consented to receive promotional communications, 35jl records your communication preferences, email open and click activity, and promotion redemption history. You may withdraw marketing consent at any time by updating your account preferences or contacting support.

35jl processes personal data only where a valid legal basis exists under the Data Privacy Act of 2012. The following table summarises the primary processing purposes and their corresponding legal bases.

35jl does not sell, rent, or otherwise transfer your personal data to third parties for their own commercial purposes. Personal data is shared only in the limited circumstances described below.

4.1 Service Providers and Processors

35jl engages third-party service providers who process personal data on our behalf under written data processing agreements. These include:

• Payment processors — GCash (GXI / Globe Fintech), Maya (Voyager Innovations), and Philippine banking partners for transaction processing;
• KYC and identity verification providers — for automated document verification and liveness detection;
• Game content providers — game studios and live casino operators whose software powers the 35jl game library receive session-level data necessary for game function;
• Cloud infrastructure providers — for secure hosting, backup, and content delivery services;
• Analytics and fraud detection services — for platform security and performance monitoring.

All third-party processors are bound by contractual obligations to process personal data only as instructed by 35jl, in compliance with the Data Privacy Act, and with appropriate security measures in place.

4.2 Regulatory and Law Enforcement Authorities

35jl may disclose personal data to Philippine government authorities, regulatory bodies, law enforcement agencies, or the courts where required to do so by law, court order, or regulatory instruction — including for anti-money laundering (AMLA) reporting obligations, tax compliance, or criminal investigation purposes.

4.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of 35jl's assets, personal data held by 35jl may be transferred to the successor entity. Players will be notified of any such transfer via the Platform and given the opportunity to close their accounts prior to the transfer if they do not consent to the new data controller's privacy practices.

4.4 No Cross-Border Transfers Without Safeguards

Where personal data is transferred to entities or service providers located outside the Philippines, 35jl ensures appropriate safeguards are in place, including contractual data transfer clauses meeting the standards required by the NPC, prior to any such transfer.

35jl retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following retention periods apply as minimum baselines:

Upon expiry of the applicable retention period, personal data is either permanently deleted from all 35jl systems or anonymised such that it can no longer be linked to any identifiable individual. Anonymised aggregated data may be retained indefinitely for analytical and reporting purposes.

35jl implements a multi-layered security framework to protect personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

6.1 Technical Measures

• Transport encryption: All data in transit between your device and 35jl servers is encrypted using TLS 1.2 or higher (256-bit SSL);
• At-rest encryption: Sensitive data stored in 35jl databases — including KYC documents and financial records — is encrypted at rest using AES-256;
• Password hashing: Account passwords are never stored in plaintext; they are hashed using industry-standard algorithms with salting;
• Access controls: Internal access to personal data is restricted on a need-to-know basis with role-based permissions and multi-factor authentication;
• Intrusion detection: Network monitoring and intrusion detection systems operate continuously to identify and respond to security incidents;
• Penetration testing: The Platform undergoes periodic third-party security assessments.

6.2 Organisational Measures

• All 35jl staff with access to personal data receive data privacy and security training;
• Data access and processing activities are logged and audited regularly;
• A designated Data Protection Officer (DPO) oversees compliance with this Policy and the Data Privacy Act;
• Third-party processors are subject to contractual security obligations and periodic review.

6.3 Security Incident Response

In the event of a personal data breach that poses a risk to your rights and freedoms, 35jl will notify the National Privacy Commission within 72 hours of becoming aware of the breach. Affected data subjects will be notified without undue delay where the breach is likely to result in a high risk to their rights, in accordance with the DPA and NPC Circular 16-03.

35jl uses cookies and similar tracking technologies on the Platform to support authentication, maintain session state, detect fraud, and improve the player experience. Cookies are small data files stored on your device by your browser when you visit the Platform.

7.1 Categories of Cookies Used

• Strictly necessary cookies: Required for the Platform to function — including session management and security tokens. These cannot be disabled without breaking Platform functionality;
• Performance cookies: Collect anonymised data on how players use the Platform to help us improve loading times and navigation;
• Functional cookies: Remember your preferences such as language settings and last-used game categories;
• Analytics cookies: Used to understand aggregate Platform usage patterns. Where possible, analytics data is processed in anonymised form.

7.2 Managing Cookies

You can control non-essential cookies through your browser settings. Instructions for managing cookies are available in the help documentation of all major browsers. Please note that disabling certain cookies may impair the functionality of the 35jl Platform, including the ability to log in and place bets.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 35jl. To exercise any of these rights, contact our Data Protection Officer at [email protected] or via live chat. 35jl will respond to rights requests within thirty (30) calendar days.

The 35jl Platform is strictly for individuals who are 21 years of age or older. We do not knowingly collect personal data from individuals under the age of 21. Age is verified during the account registration process, and accounts where underage use is confirmed will be closed immediately.

If you believe that a minor has registered an account or provided personal data to 35jl, please contact our support team immediately. We will promptly investigate and, where confirmed, delete all personal data relating to the minor and close the account.

35jl sends promotional communications — including bonus offers, tournament invitations, loyalty programme updates, and game announcements — only to players who have given explicit consent to receive them. Consent to receive marketing communications is collected at registration and can be updated at any time from your account preferences.

10.1 Withdrawing Marketing Consent

You may withdraw your consent to receive promotional communications at any time by:

• Updating your communication preferences in your 35jl account settings;
• Clicking the unsubscribe link included in any 35jl marketing email;
• Contacting the 35jl support team via live chat or email.

Withdrawal of marketing consent does not affect the lawfulness of processing carried out prior to withdrawal. Operational communications — such as transaction confirmations, security alerts, and account notifications — are not subject to marketing consent and will continue regardless of your marketing preference settings.

35jl reserves the right to amend this Privacy Policy at any time. Material changes — those that significantly affect how we collect or use your personal data, or materially affect your rights — will be communicated via a prominent notice on the Platform and/or by email to your registered address at least fourteen (14) calendar days before the amendment takes effect.

Non-material updates, such as clarifications of existing provisions or corrections of typographical errors, may be made without prior notice. The effective date at the top of this Policy reflects the date of the most recent update. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

35jl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and the Philippine Data Privacy Act. To exercise your data subject rights, report a privacy concern, or make a formal complaint regarding 35jl's data processing practices, please contact the DPO through:

• Email: [email protected] — subject line: "Data Privacy Request"
• Live Chat: Available 24/7 via the support widget on the Platform

35jl will acknowledge receipt of all data subject rights requests within five (5) business days and provide a substantive response within thirty (30) calendar days. If your request is complex or requires additional time to process, you will be notified of the reason for the extension.

If you are not satisfied with 35jl's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information on how to file a complaint is available on the NPC's official channels.