36jl98 Casino —
Privacy Policy & Data Protection Notice

1. Introduction

This Privacy Policy ("Policy") describes how 36jl98 ("we," "us," "our") collects, uses, stores, shares, and protects the personal information of users ("you," "your," "Player") who register for and use the 36jl98 online gaming platform accessible at https://36jl98.cam and its associated services (collectively, the "Platform").

36jl98 is the Philippines' premier Black Diamond VIP online casino and sports betting platform. As a platform serving Filipino players across Metro Manila, Cebu, Davao, Quezon City, Makati, and nationwide, we take our obligations under Philippine data protection law with the utmost seriousness. We do not treat privacy compliance as a checkbox exercise — it is a fundamental part of how we operate and how we earn the trust of our players.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy. Together, these documents govern your entire relationship with the 36jl98 Platform.

2. Legal Basis and Regulatory Framework

36jl98 processes personal data in compliance with the following Philippine laws and regulatory frameworks:

• Republic Act No. 10173 — Data Privacy Act of 2012 (DPA) and its Implementing Rules and Regulations (IRR)
• National Privacy Commission (NPC) — Circulars, advisories, and guidelines issued by the NPC as the data protection authority of the Philippines
• Republic Act No. 9160 — Anti-Money Laundering Act (AMLA), as amended, which requires the collection and retention of certain personal and transactional data
• PAGCOR Regulations — Philippine Amusement and Gaming Corporation licensing conditions requiring KYC data collection and player account verification
• Republic Act No. 10175 — Cybercrime Prevention Act of 2012, governing cybersecurity obligations relevant to the protection of personal data stored electronically

Where any provision of this Policy conflicts with applicable Philippine law, the requirements of Philippine law shall prevail.

3. Personal Data We Collect

The categories of personal data that 36jl98 collects about you depend on how you interact with the Platform. The following table summarizes the main categories:

3.1 Sensitive Personal Information

Certain data we collect may qualify as "sensitive personal information" under the Data Privacy Act, including government ID numbers and financial account details. 36jl98 applies heightened protection standards to this category of data and processes it only to the extent strictly required for regulatory compliance and service delivery.

4. How We Collect Your Personal Data

36jl98 collects personal data through the following channels:

• Direct collection: Information you voluntarily provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or responding to promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including via cookies, server logs, and session tracking technologies.
• Third-party sources: Identity verification data from PAGCOR-approved KYC service providers; payment verification data from GCash, PayMaya, and banking partners; fraud screening data from licensed third-party risk management services.
• Publicly available sources: Where permitted by law and necessary for fraud prevention or AML compliance, we may consult publicly available records.

5. How We Use Your Personal Data

36jl98 uses the personal data it collects for the following purposes:

1. Account creation and management: To register your account, verify your identity, and maintain your player profile on the 36jl98 Platform.
2. KYC and age verification: To confirm that you are at least 21 years of age and to verify your identity in compliance with PAGCOR and AMLA requirements.
3. Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other accepted payment channels in Philippine Pesos (PHP).
4. Game delivery: To provide access to all 36jl98 Platform games including slots, live casino, sports betting, sabong streaming, Tongits Go, Bingo, and Blackjack MH.
5. Customer support: To respond to inquiries, resolve disputes, and provide 24/7 assistance through our Filipino-speaking support team.
6. Security and fraud prevention: To detect, investigate, and prevent unauthorized access, fraudulent activity, money laundering, and other illegal conduct.
7. Regulatory compliance: To fulfill our obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act, and all other applicable Philippine laws.
8. Responsible gaming: To monitor gameplay patterns for signs of problem gambling, enforce deposit and loss limits, and facilitate self-exclusion requests.
9. Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent or where permitted by law. You may opt out of marketing communications at any time.
10. Platform improvement: To analyze usage patterns, optimize game performance, and develop new features that better serve Filipino players.

6. Legal Grounds for Processing

Under the Data Privacy Act of 2012, 36jl98 processes your personal data on the following lawful bases:

• Performance of a contract: Processing necessary to deliver the services you requested when you registered your 36jl98 account, including game access, payment processing, and account management.
• Compliance with a legal obligation: Processing required to comply with PAGCOR regulations, AMLA reporting obligations, NPC guidelines, and other mandatory Philippine legal requirements.
• Legitimate interests: Processing for fraud prevention, security monitoring, responsible gaming oversight, and platform improvement — where these interests are not overridden by your fundamental rights.
• Consent: Processing for optional purposes such as marketing communications and the use of non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing and Disclosure

7.1 Third Parties We Share Data With

36jl98 does not sell your personal data to third parties for their own marketing purposes. We share personal data only in the following circumstances and only to the extent strictly necessary:

• Payment processors: GCash, PayMaya, and banking partners (BPI, BDO, Metrobank) receive necessary financial data to process your transactions.
• KYC and identity verification providers: PAGCOR-approved KYC service providers receive identity documents to complete verification.
• Game providers: JILI, PG Soft, Evolution Gaming, Pragmatic Play, and other certified game developers may receive your player ID and session data to deliver their games.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies receive data as required by law, court order, or regulatory direction.
• Fraud prevention and security services: Licensed third-party providers that assist with risk scoring, fraud detection, and cybersecurity.
• IT infrastructure and cloud providers: Technology providers hosting the 36jl98 Platform under binding data processing agreements that require compliance with Philippine data protection standards.

7.2 Data Processing Agreements

All third-party processors who handle personal data on behalf of 36jl98 are required to enter into binding data processing agreements obligating them to protect your data with standards equivalent to those applied by 36jl98 itself.

8. Data Retention

36jl98 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to any mandatory retention periods imposed by Philippine law. The following general retention periods apply:

• Active account data: Retained for the duration of your account with 36jl98 and for a minimum of five (5) years following account closure, as required by AMLA and PAGCOR regulations.
• KYC and identity documents: Retained for a minimum of five (5) years following the end of the business relationship, in compliance with AMLA requirements.
• Transaction records: Retained for a minimum of five (5) years following the transaction date, as required by AMLA.
• Customer support communications: Retained for three (3) years following the closure of the support case.
• Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents reconstruction of your identity.

9. Data Security

36jl98 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security measures include, but are not limited to:

• End-to-end encryption using industry-standard TLS/SSL protocols for all data transmitted between your device and the 36jl98 Platform.
• Encryption of sensitive data at rest, including financial records and KYC documents, using AES-256 or equivalent encryption standards.
• Strict role-based access controls limiting internal access to personal data on a need-to-know basis.
• Multi-factor authentication requirements for all internal systems that process personal data.
• Regular security audits, penetration testing, and vulnerability assessments conducted by qualified cybersecurity professionals.
• Secure data centers with physical access controls, CCTV monitoring, and environmental safeguards.
• Incident response procedures compliant with NPC data breach notification requirements (72-hour notification obligation for qualifying breaches).

While we implement robust security measures, no system is completely immune to cybersecurity risks. You play an important role in your own data security by keeping your 36jl98 account password confidential and using a strong, unique password.

10. Cookies and Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 36jl98 Platform. They allow the Platform to recognize your device, remember your preferences, maintain your session, and collect analytical data about Platform usage.

10.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These enable you to log in, maintain your game session, and use core features. These cookies cannot be disabled.
• Functional cookies: Remember your preferences, such as your language settings and previously entered information, to improve your experience.
• Analytical cookies: Collect anonymized data about how you use the Platform to help us understand player behavior and improve our services.
• Security cookies: Used for fraud prevention, bot detection, and to protect against unauthorized account access.

10.3 Cookie Management

You can manage non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 36jl98 Platform. For detailed cookie settings, refer to your browser's help documentation.

11. Your Rights Under the Data Privacy Act

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 36jl98. To exercise any of these rights, contact our Data Protection Officer using the details in Section 16.

12. Children's Privacy and Age Restriction

The 36jl98 Platform is strictly prohibited for use by persons under twenty-one (21) years of age. 36jl98 does not knowingly collect, process, or retain personal data belonging to minors. We enforce this restriction through mandatory KYC verification that requires submission of a valid Philippine government-issued ID confirming the player's date of birth.

If 36jl98 discovers that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, forfeit any balances, and delete all collected personal data associated with that account to the extent not required to be retained by law.

Parents and guardians who believe their minor child may have registered on 36jl98 are urged to contact our customer support team or Data Protection Officer immediately.

13. Cross-Border Data Transfers

In the course of delivering our services, certain personal data may be transferred to and processed in jurisdictions outside the Philippines — for example, by game providers or cloud infrastructure partners with servers in other countries. When such transfers occur, 36jl98 ensures they are conducted only:

• To recipients in countries recognized by the National Privacy Commission as providing adequate data protection, or
• Under binding contractual agreements that impose data protection obligations equivalent to those required under Philippine law, or
• With your explicit consent after being informed of the risks.

All third-party recipients of personal data are required to handle that data in a manner consistent with 36jl98's privacy commitments and applicable Philippine law.

14. Third-Party Links

The 36jl98 Platform may contain references to third-party game providers and payment services. These third parties operate their own privacy policies independently of 36jl98. When you interact with a third-party service embedded within or linked from the Platform, your personal data may be processed by that third party under their own terms.

36jl98 is not responsible for the privacy practices of third-party providers. We recommend reviewing the privacy policies of any third-party services you interact with through the Platform.

15. Changes to This Privacy Policy

36jl98 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal obligations, or regulatory requirements. When material changes are made, we will update the "Last Updated" date at the top of this Policy and, where required by the Data Privacy Act or NPC guidelines, notify affected players via email or prominent on-Platform notice.

For non-material changes (such as minor clarifications or formatting updates), we may update this Policy without separate notification. Your continued use of the Platform following any change constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

16. Contact and Data Protection Officer

36jl98 has designated a Data Protection Officer (DPO) in compliance with Section 21 of the Data Privacy Act and its Implementing Rules. If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to report a privacy concern, please contact:

• Data Protection Officer, 36jl98
• Email: [email protected] (mark subject: "Data Privacy / DPO Inquiry")
• Live Chat: Available 24/7 via the Platform
• Response Time: We will acknowledge your request within 72 hours and provide a substantive response within thirty (30) days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines at privacy.gov.ph.