Privacy Policy — 963jl Casino Philippines

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 963jl ("we," "us," "our," or "963jl"), the operator of the online gaming platform accessible at https://963jl.cam, collects, uses, discloses, stores, and protects the personal information of its users ("you," "your," or "Player") in connection with your use of the 963jl website, mobile applications, and all related services (collectively, the "Platform").

963jl is committed to protecting the privacy and personal data of all Filipino players in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and all applicable issuances of the National Privacy Commission (NPC). We also align our practices with PAGCOR's regulatory requirements for data handling in licensed online gaming operations.

This Policy applies to all personal data processed by 963jl in connection with your registration, use of the Platform, participation in games, transactions, and communications with our support team. By accessing the Platform or creating an account, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

If you do not agree to this Policy, please do not use the 963jl Platform. This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy.

2. Data Controller Information

963jl is the data controller responsible for your personal data collected and processed through the Platform. As data controller, we determine the purposes and means of processing your personal information.

For all privacy-related inquiries, requests, or concerns, you may contact our designated Data Protection Officer (DPO) through the following:

Data Protection Officer — 963jl
Email: [email protected]
Subject line: "Privacy / DPO Request"
Response time: Within 15 business days of receipt

3. Personal Data We Collect

963jl collects personal data that is necessary, adequate, and relevant to the purposes for which it is processed. The categories of personal data we collect include, but are not limited to, the following:

3.1 Identity and Contact Information

• Full legal name (first, middle, and last name)
• Date of birth and age verification information
• Gender
• Residential address (including city, province, and ZIP code)
• Email address
• Mobile phone number
• Government-issued identification document type and number (e.g., Philippine passport, driver's license, UMID, Postal ID, PhilSys National ID)

3.2 Financial and Transaction Information

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method identifiers
• GCash mobile number or Maya account reference
• Bank account name and last four digits (where provided)
• Credit or debit card type and last four digits (if used for deposits)
• Account balance history
• Bonus and promotional activity records

3.3 Gaming and Behavioral Data

• Game session logs, including games played, bet amounts, outcomes, and session duration
• Wagering history and cumulative totals
• Responsible gaming settings and self-exclusion requests
• Deposit limit configurations
• Bonus claims and wagering fulfillment progress

3.4 Technical and Device Data

• IP address and geolocation data (city/region level)
• Device type, operating system, and browser type and version
• Unique device identifiers
• Login timestamps and session activity logs
• Referral source and UTM parameters (if applicable)

3.5 Communications Data

• Records of live chat conversations with our support team
• Email correspondence with 963jl
• Feedback, survey responses, and complaint records

4. How We Collect Your Data

We collect personal data through the following means:

4.1 Directly From You

• Account registration: When you create a 963jl account, you provide identity, contact, and age verification information.
• KYC verification: When you submit identity documents in connection with withdrawal requests or account verification.
• Deposits and withdrawals: When you initiate financial transactions, payment-related data is collected.
• Support interactions: When you contact our customer support team via live chat or email.
• Promotions and surveys: When you participate in promotional activities, competitions, or voluntarily complete surveys.

4.2 Automatically Through the Platform

• Server logs automatically capture IP addresses, device information, and session data when you access the Platform.
• Cookies and similar tracking technologies collect browsing behavior and preference data (see Section 8).
• Game engines log all bet placements, outcomes, and session activity for integrity and dispute resolution purposes.

4.3 From Third Parties

• Payment processors: Transaction confirmation and fraud screening data from GCash, Maya, and banking partners.
• Identity verification services: Age and identity confirmation data from licensed KYC/AML service providers.
• PAGCOR: Regulatory compliance data as required under our operating license.

5. Legal Bases for Processing

Under the Data Privacy Act of 2012 and its IRR, 963jl processes your personal data on one or more of the following legal bases:

Legal Basis	Examples of Processing Activities
Performance of a Contract	Account creation, processing deposits and withdrawals, providing gaming services, resolving disputes
Compliance with a Legal Obligation	KYC/AML verification, PAGCOR reporting, tax compliance, data breach notifications to the NPC
Legitimate Interest	Fraud prevention, platform security, responsible gaming monitoring, service improvement analytics
Consent	Marketing communications, non-essential cookies, participation in optional surveys or promotions
Vital Interests	Protecting a player from immediate harm identified through responsible gaming monitoring

6. How We Use Your Data

963jl uses the personal data we collect for the following purposes:

6.1 Account Management and Service Delivery

• Creating, verifying, and maintaining your 963jl player account
• Processing deposits, withdrawals, and account balance adjustments
• Providing access to games, promotions, and platform features
• Authenticating your identity when you log in

6.2 Legal and Regulatory Compliance

• Verifying that you meet the minimum age requirement of 21 years
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by PAGCOR and Philippine law
• Fulfilling reporting obligations to PAGCOR and other competent authorities
• Maintaining records as required under Philippine financial and gaming regulations

6.3 Fraud Prevention and Platform Security

• Detecting and preventing fraudulent transactions, bonus abuse, and multi-account violations
• Monitoring for unauthorized access attempts and suspicious account activity
• Investigating complaints, disputes, and potential terms violations

6.4 Responsible Gaming

• Monitoring gaming patterns for signs of problem gambling behavior
• Enforcing self-exclusion and deposit limit configurations
• Contacting players identified as potentially at-risk, where appropriate

6.5 Customer Support and Communications

• Responding to your support inquiries, complaints, and account-related requests
• Sending transactional communications such as deposit confirmations, withdrawal notifications, and account alerts
• Sending promotional communications (only where you have opted in or where permitted under applicable law)

6.6 Platform Improvement and Analytics

• Analyzing aggregated, anonymized usage data to improve platform performance and user experience
• Conducting internal research and development
• Testing new features and services prior to wider deployment

7. Disclosure to Third Parties

963jl does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary and on a need-to-know basis:

7.1 Service Providers and Data Processors

We engage trusted third-party service providers who process personal data on our behalf, including:

• Payment processors: GCash, Maya, BancNet-affiliated banks, and card networks (Visa, Mastercard) for transaction processing
• KYC/AML providers: Licensed identity verification services for age and identity checks
• Cloud hosting and infrastructure providers: Secure server and data storage services
• Customer support platforms: Live chat and ticketing systems used to manage support interactions
• Analytics providers: Aggregated, anonymized platform analytics services

All third-party data processors are bound by data processing agreements that require them to process personal data only on our instructions and in compliance with applicable data protection law.

7.2 Regulatory Authorities

We may be required to disclose personal data to:

• PAGCOR and other Philippine gaming regulatory bodies
• Anti-Money Laundering Council (AMLC) in connection with AML obligations
• National Privacy Commission (NPC) in connection with data breach notifications or NPC investigations
• Courts, law enforcement, or government agencies where disclosure is required by law, court order, or valid legal process

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving 963jl, personal data may be transferred to the relevant counterparty as part of that transaction, subject to equivalent privacy protections. You will be notified of any such transfer and the identity of the new data controller.

8. Cookies and Tracking Technologies

963jl uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize your browser, remember your preferences, and collect analytical data.

8.1 Types of Cookies We Use

Cookie Type	Purpose	Consent Required?
Strictly Necessary	Session management, login authentication, security tokens	No — essential for platform operation
Functional	Remembering language preferences, display settings	No — improves your experience
Analytical	Aggregated usage statistics to improve the Platform	Yes — opt-in via cookie banner
Marketing	Personalizing promotional content and tracking campaign performance	Yes — opt-in only

You may manage your cookie preferences at any time through your browser settings. Disabling certain cookies may affect the functionality of the Platform. For more information, refer to your browser's help documentation.

9. Data Retention

963jl retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. Our general retention schedule is as follows:

• Active account data: Retained for the duration of your account and for 5 years after account closure, in compliance with PAGCOR record-keeping requirements and AMLC obligations.
• Transaction records: Retained for a minimum of 5 years from the date of the transaction, as required by Philippine anti-money laundering laws.
• KYC and identity documents: Retained for 5 years from the date of the last transaction or account closure, whichever is later.
• Customer support records: Retained for 2 years from the date of resolution, or longer if the matter involves ongoing legal proceedings.
• Marketing consent records: Retained for 3 years from the date consent was given or withdrawn.
• Technical and server logs: Retained for 12 months, unless required for longer for security investigations.

Upon expiration of the applicable retention period, personal data will be securely deleted, anonymized, or archived in a manner that prevents re-identification.

10. Data Security Measures

963jl implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security measures include:

• Encryption: All data in transit is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest is encrypted using AES-256.
• Access controls: Access to personal data is restricted to authorized personnel on a need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Network security: Our infrastructure is protected by firewalls, intrusion detection systems, and regular penetration testing conducted by independent security firms.
• Payment security: Financial transactions are processed through PCI-DSS Level 1 certified payment gateways. 963jl does not store full payment card details.
• Staff training: All 963jl personnel who handle personal data receive regular data protection training and are bound by confidentiality obligations.
• Incident response: We maintain a documented data breach response plan and will notify affected players and the NPC within 72 hours of discovering a breach that poses a risk to your rights.

While 963jl takes all reasonable precautions to protect your personal data, no internet transmission or electronic storage system is 100% secure. You use the Platform at your own risk and are responsible for keeping your login credentials confidential.

11. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its IRR, you have the following rights in relation to your personal data held by 963jl:

11.1 Right to Be Informed

You have the right to be informed about how your personal data is collected, used, and disclosed. This Privacy Policy fulfills that obligation.

11.2 Right to Access

You may request a copy of the personal data we hold about you, along with information about how it is being processed. Requests will be fulfilled within 15 business days.

11.3 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. You may update basic account information directly through your account settings; for KYC-related data corrections, contact our support team.

11.4 Right to Erasure or Blocking

You may request the deletion or blocking of your personal data where it is no longer necessary for the purpose it was collected, where consent has been withdrawn, or where processing is unlawful. Note that this right is subject to our legal retention obligations — we cannot delete data we are required by law to retain.

11.5 Right to Data Portability

You have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format. This right applies to data you have provided to us directly and which is processed on the basis of your consent or contract performance.

11.6 Right to Object

You have the right to object to the processing of your personal data for marketing purposes. You may opt out of marketing communications at any time by contacting our support team or using the unsubscribe mechanism in any marketing email.

11.7 Right to Lodge a Complaint

If you believe that 963jl has violated your data privacy rights, you may lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint is available on the NPC's official government website.

To exercise any of the above rights, contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." We may require verification of your identity before processing your request.

12. Children's Privacy

The 963jl Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete such data and close the associated account.

If you are a parent or guardian and believe that a minor may have created an account or provided personal data to 963jl, please contact us immediately at [email protected].

13. Cross-Border Data Transfers

963jl primarily processes personal data within the Philippines. Where it is necessary to transfer personal data to third-party service providers located outside the Philippines (for example, cloud infrastructure or technology partners), we ensure that such transfers are conducted:

• In compliance with Section 21 of the Data Privacy Act of 2012 and NPC rules on cross-border transfers;
• With adequate contractual safeguards in place, such as standard contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under Philippine law;
• Only to countries or organizations that have been assessed to provide an adequate level of protection for personal data.

You may request further information about specific cross-border data transfers by contacting our Data Protection Officer.

14. Changes to This Privacy Policy

963jl reserves the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page, and the "Last Updated" date at the top of the Policy will reflect the date of the most recent revision. For material changes that significantly affect how we process your personal data, we will provide additional notice through a platform notification or email to your registered address.

Your continued use of the 963jl Platform following the posting of any changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

15. Contact and Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 963jl, please contact our Data Protection Officer:

Data Protection Officer — 963jl
Email: [email protected]
Subject Line: "Privacy / DPO Request"
Live Chat: Available 24/7 through the 963jl Platform
Response Time: Within 15 business days of receipt