Privacy Policy – 39jl.com

Last Updated: January 1, 2026

39jl.com ("Company", "We", "Us", "Our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, store, and protect the personal data you provide when you access or use the 39jl.com platform ("Platform"), including our website and mobile applications. This Privacy Policy applies to all users of the Platform and should be read in conjunction with our Terms and Conditions. By using the 39jl.com Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

39jl.com operates in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and other applicable data protection regulations. We are committed to ensuring that your personal information is handled responsibly, securely, and in accordance with the highest standards of data protection.

1. Information We Collect

39jl.com collects various types of personal information from users to provide, maintain, and improve our services, ensure compliance with legal and regulatory requirements, and enhance your overall gaming experience. The types of information we collect include:

1.1 Personal Identification Information

When you register an account on 39jl.com, we collect personal identification information necessary to verify your identity and comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations. This information includes:

• Full legal name as it appears on your government-issued identification document
• Date of birth to verify that you meet the minimum age requirement of 21 years
• Gender
• Nationality and country of residence
• Residential address, including street address, city, province, and postal code
• Email address for account communications and notifications
• Mobile phone number for account verification and two-factor authentication
• Government-issued identification documents such as Philippine passport, driver's license, SSS ID, UMID, or other acceptable forms of ID
• Selfie or photograph holding your identification document for identity verification purposes

1.2 Financial Information

To process deposits, withdrawals, and other financial transactions on the Platform, we collect financial information, including:

• Payment method details such as GCash account number, PayMaya account number, or bank account information (account number, bank name, account holder name)
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment methods used
• Source of funds documentation when required for enhanced due diligence or AML compliance

Please note that 39jl.com does not store full credit card numbers or CVV codes. Payment processing is handled by secure third-party payment processors that comply with PCI-DSS (Payment Card Industry Data Security Standard) requirements.

1.3 Account and Gaming Activity Information

We collect information related to your use of the Platform and your gaming activities, including:

• Account login history, including IP addresses, device information, and timestamps
• Gaming activity, including games played, bets placed, winnings, losses, and bonus usage
• Communication history with our customer support team, including live chat transcripts, emails, and support tickets
• Preferences and settings you configure on your account
• Responsible gaming tool usage, such as deposit limits, session time limits, and self-exclusion requests

1.4 Technical and Device Information

When you access the 39jl.com Platform, we automatically collect certain technical information about your device and how you interact with the Platform, including:

• IP address and geolocation data to verify your location and ensure compliance with jurisdictional restrictions
• Device type, operating system, browser type, and version
• Screen resolution, language preferences, and time zone settings
• Cookies, web beacons, and similar tracking technologies (see Section 8 for more details)
• Referral source (e.g., how you found our website, such as through a search engine, advertisement, or affiliate link)
• Pages visited, links clicked, and time spent on the Platform

1.5 Marketing and Communication Preferences

If you opt in to receive marketing communications from 39jl.com, we collect information about your communication preferences, including:

• Email subscription status and preferences
• SMS/text message subscription status
• Push notification preferences for mobile app users
• Engagement with marketing emails, such as open rates and click-through rates

2. How We Use Your Information

39jl.com uses the personal information we collect for the following purposes:

2.1 Account Management and Service Provision

• To create, maintain, and manage your user account on the Platform
• To verify your identity and age to ensure compliance with legal requirements and prevent underage gambling
• To process deposits, withdrawals, and other financial transactions
• To provide customer support and respond to your inquiries, complaints, or requests
• To enable you to participate in gaming activities, including casino games, live dealer games, sports betting, and other offerings on the Platform

2.2 Legal and Regulatory Compliance

• To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations as required by Philippine law and PAGCOR
• To detect, prevent, and investigate fraud, money laundering, terrorist financing, and other illegal activities
• To comply with legal obligations, court orders, subpoenas, or requests from law enforcement or regulatory authorities
• To enforce our Terms and Conditions and other policies

2.3 Platform Improvement and Analytics

• To analyze user behavior and preferences to improve the Platform's functionality, user experience, and game offerings
• To conduct research, statistical analysis, and data analytics to understand trends and optimize our services
• To test new features, products, and services before launching them to all users

2.4 Marketing and Promotional Communications

• To send you promotional offers, bonuses, newsletters, and other marketing communications if you have opted in to receive such communications
• To personalize marketing content based on your gaming preferences and activity
• To notify you about new games, features, tournaments, and special events on the Platform

2.5 Security and Fraud Prevention

• To monitor and detect suspicious activity, unauthorized access, or potential security breaches
• To protect the integrity of the Platform and prevent cheating, collusion, or other forms of gaming fraud
• To enforce responsible gaming policies and identify users who may be at risk of problem gambling

3. How We Share Your Information

39jl.com does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients under specific circumstances:

3.1 Service Providers and Business Partners

We may share your personal information with trusted third-party service providers who assist us in operating the Platform, processing payments, conducting KYC verification, providing customer support, and delivering other services. These service providers include:

• Payment processors (e.g., GCash, PayMaya, bank payment gateways) to facilitate deposits and withdrawals
• Identity verification and KYC service providers to verify your identity and comply with regulatory requirements
• Cloud hosting and data storage providers to securely store your information
• Customer support platforms and live chat service providers
• Marketing and email service providers to send promotional communications (only if you have opted in)
• Analytics and data processing providers to analyze Platform usage and improve our services

All third-party service providers are contractually obligated to protect your personal information and use it only for the purposes for which it was disclosed. They are prohibited from using your information for their own purposes or sharing it with other parties without our authorization.

3.2 Legal and Regulatory Authorities

We may disclose your personal information to law enforcement agencies, regulatory authorities, courts, or other government entities if required by law or if we believe in good faith that such disclosure is necessary to:

• Comply with legal obligations, court orders, subpoenas, or regulatory requests
• Investigate, prevent, or take action regarding suspected illegal activities, fraud, or violations of our Terms and Conditions
• Protect the rights, property, or safety of 39jl.com, our users, or the public
• Respond to claims that any content on the Platform violates the rights of third parties

3.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor organization. We will notify you via email or a prominent notice on the Platform before your information is transferred and becomes subject to a different privacy policy.

3.4 With Your Consent

We may share your personal information with third parties if you have provided explicit consent for such disclosure. For example, if you participate in a promotion or tournament sponsored by a third party, we may share your information with that sponsor as necessary to administer the promotion.

4. Data Security

39jl.com takes the security of your personal information seriously and employs industry-standard technical, administrative, and physical safeguards to protect your data from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using SSL/TLS (Secure Socket Layer / Transport Layer Security) protocols to prevent interception by unauthorized parties.
• Secure Data Storage: Personal information is stored on secure servers with restricted access. We use firewalls, intrusion detection systems, and other security technologies to protect our infrastructure.
• Access Controls: Access to personal information is limited to authorized personnel who require such access to perform their job functions. All employees and contractors with access to personal data are bound by confidentiality obligations.
• Two-Factor Authentication (2FA): We offer optional two-factor authentication to add an extra layer of security to your account.
• Regular Security Audits: We conduct regular security audits and vulnerability assessments to identify and address potential security risks.
• Incident Response: We have established incident response procedures to quickly detect, respond to, and mitigate security breaches or data incidents.

While we implement robust security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you acknowledge that you provide your personal information at your own risk. If you become aware of any security breach or unauthorized access to your account, please contact us immediately.

5. Data Retention

39jl.com retains your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. The retention periods vary depending on the type of information and the purpose for which it was collected:

• Account Information: We retain your account information for the duration of your active account and for a period of at least five (5) years after account closure, as required by Philippine AML regulations and PAGCOR guidelines.
• Transaction Records: Financial transaction records, including deposits, withdrawals, and gaming activity, are retained for at least five (5) years from the date of the transaction to comply with AML and tax reporting requirements.
• KYC Documents: Identity verification documents are retained for at least five (5) years after account closure or the last transaction, whichever is later.
• Communication Records: Customer support communications, including live chat transcripts and emails, are retained for up to three (3) years for quality assurance and dispute resolution purposes.
• Marketing Data: If you unsubscribe from marketing communications, we will retain your email address on a suppression list to ensure we do not contact you again, unless you re-subscribe.

After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with our data retention and disposal policies.

6. Your Rights Under Philippine Data Privacy Law

Under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights regarding your personal information:

• Right to Access: You have the right to request access to the personal information we hold about you and obtain a copy of such information.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal information.
• Right to Erasure: You have the right to request deletion of your personal information, subject to legal and regulatory retention requirements.
• Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes or other legitimate interests.
• Right to Data Portability: You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: If we process your personal information based on your consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact our Data Protection Officer using the contact information provided in Section 10. We will respond to your request within thirty (30) days. Please note that certain requests may be subject to verification of your identity and may be limited by legal or regulatory obligations.

7. International Data Transfers

39jl.com primarily operates within the Philippines and stores your personal information on servers located in the Philippines or in secure data centers operated by our cloud service providers. In some cases, your personal information may be transferred to, stored, or processed in countries outside the Philippines where our service providers or business partners are located. When we transfer your personal information internationally, we ensure that appropriate safeguards are in place to protect your data in accordance with Philippine data protection laws and international standards.

8. Cookies and Tracking Technologies

39jl.com uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize your browser and remember certain information about your preferences and activity.

Types of Cookies We Use:

• Essential Cookies: These cookies are necessary for the Platform to function properly and cannot be disabled. They enable core functionality such as account login, session management, and security features.
• Performance Cookies: These cookies collect information about how you use the Platform, such as which pages you visit and how long you spend on each page. This information is used to improve the Platform's performance and user experience.
• Functional Cookies: These cookies remember your preferences and settings, such as language preference, to provide a more personalized experience.
• Marketing Cookies: These cookies track your browsing activity across websites to deliver targeted advertisements and measure the effectiveness of marketing campaigns.

You can manage your cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of the Platform and your ability to access certain features.

9. Third-Party Links

The 39jl.com Platform may contain links to third-party websites, services, or applications that are not operated or controlled by 39jl.com. This Privacy Policy does not apply to third-party websites, and we are not responsible for the privacy practices or content of such sites. We encourage you to review the privacy policies of any third-party websites you visit.

10. Contact Information and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact our Data Protection Officer:

Data Protection Officer
39jl.com
Email: [email protected]

We are committed to addressing your concerns and resolving any privacy-related issues in a timely and transparent manner.

11. Changes to This Privacy Policy

39jl.com reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Any changes will be effective immediately upon posting the revised Privacy Policy on the Platform. We will notify you of material changes by email or through a prominent notice on the Platform. Your continued use of the Platform after the posting of changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

By using the 39jl.com Platform, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy.