345jl Privacy Policy

345jl is committed to protecting the privacy and personal data of every player who uses our platform. This Privacy Policy explains, in plain terms, exactly what information 345jl collects about you, why we collect it, how we use it, how long we keep it, and what rights you have over your own data under Philippine law.

This policy applies to all personal data collected through the 345jl website at 345jl.app, the 345jl account registration and login system, the game platform and associated features, the customer support system, and all marketing communications sent by or on behalf of 345jl. It applies to all users who access the platform from the Philippines, which constitutes our primary market, as well as to users accessing from any other territory where use of the platform is legally permitted.

We have written this policy to comply with Republic Act No. 10173 (the Philippine Data Privacy Act of 2012), its Implementing Rules and Regulations, the National Privacy Commission's (NPC) guidelines and advisories, and the data governance requirements imposed by the Philippine Amusement and Gaming Corporation (PAGCOR) as a condition of our operating license.

For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, the data controller responsible for your personal information is the operator of the 345jl platform, regulated by PAGCOR and operating under Philippine law.

As the personal information controller, 345jl determines the purposes for which and the means by which your personal data is processed. All data processing described in this Privacy Policy is conducted by 345jl directly or by contracted third-party processors operating under written data processing agreements that impose obligations equivalent to those required of 345jl under Philippine data protection law.

Questions, requests, and complaints regarding this Privacy Policy or the handling of your personal data should be directed to the 345jl Data Privacy Officer at: [email protected] — subject line: "Data Privacy Inquiry."

345jl collects personal data in the following categories. We only collect data that is necessary for the purposes described in Section 5 of this policy (principle of proportionality under R.A. 10173).

• Full legal name as it appears on a government-issued Philippine identification document
• Date of birth (used to verify the 21+ age requirement mandated by PAGCOR)
• Email address (primary communication channel for account notifications)
• Philippine mobile number (used for OTP authentication and account security)
• Username selected during registration
• Encrypted password (stored in hashed form; plain-text passwords are never stored or accessible by 345jl staff)

• Scanned image or photograph of a valid Philippine government-issued identification document (UMID, PhilSys ID, passport, LTO driver's license, or COMELEC voter's ID)
• Selfie photograph taken for biometric comparison against the submitted identification document, where required by our KYC process
• Proof of address documentation, where requested as part of enhanced due diligence
• Source of funds documentation, where requested for Anti-Money Laundering compliance

• GCash account number or registered mobile number associated with GCash or PayMaya transactions
• Bank account details (for BPI, BDO, or Metrobank withdrawals) — account name and account number only; full card data is never stored on 345jl systems
• Complete record of all deposits made into your 345jl account, including amounts, timestamps, and payment method used
• Complete record of all withdrawals requested and processed, including amounts, timestamps, destination accounts, and processing status
• Bonus credits received, wagering progress against bonus conditions, and bonus settlement records

• Detailed records of all game sessions, including game titles played, bets placed, outcomes, session duration, and balances before and after each session
• Sports betting records including markets selected, odds accepted, bet amounts, and settlement outcomes
• Responsible gaming settings configured on your account, including any deposit limits, loss limits, or self-exclusion status

• IP address at the time of each login and significant account action
• Device type, operating system, and browser version
• Session timestamps, login duration, and logout events
• Cookie identifiers and session tokens (see Section 10)
• Geolocation data derived from IP address (country and approximate region level; precise GPS location is not collected)

• Records of all communications between you and 345jl customer support, including chat transcripts, email correspondence, and any documents you submit in connection with a support request or dispute
• Records of marketing emails and push notifications sent to your registered address, including open and click data where applicable

345jl collects personal data through the following means:

• Directly from you — through the account registration form, the KYC document submission process, the Cashier section when you make deposits or withdrawals, the customer support chat and email system, and any forms you complete on the platform.
• Automatically during platform use — through server logs that capture IP addresses and session data, browser and device fingerprinting for fraud detection and session security, and through cookies and similar tracking technologies described in Section 10.
• From third-party service providers — including identity verification services used to cross-check KYC documents, payment processors who confirm the status of deposit and withdrawal transactions, and game providers who record betting activity within their certified game systems.
• From regulatory and law enforcement sources — where required by PAGCOR, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities, 345jl may receive information about a player's risk profile or regulatory status from those authorities.

345jl processes your personal data for the following purposes. For each purpose, we identify the primary data categories used:

Purposes marked "Mandatory" are required either by law, by PAGCOR licensing conditions, or as a necessary condition of providing the 345jl service. If you decline to provide data required for mandatory purposes, 345jl may be unable to provide some or all of the services available on the platform.

Under the Philippine Data Privacy Act, 345jl processes personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and 345jl — specifically, to operate your account, process financial transactions, and provide access to the gaming platform you have registered to use.
• Legal obligation: Processing required to comply with applicable Philippine law, including obligations under the Anti-Money Laundering Act, PAGCOR licensing requirements, the National Privacy Commission's regulations, and any lawful order from a competent Philippine regulatory or law enforcement authority.
• Legitimate interests: Processing for fraud detection, platform security, abuse prevention, and aggregate analytics, where 345jl has assessed that these interests are not overridden by your data protection rights.
• Consent: Processing for optional purposes such as marketing communications, where 345jl will seek your express, informed, freely given, and specific consent before processing begins. You may withdraw consent for marketing at any time by updating your communication preferences in your account settings.

345jl does not sell, rent, or trade your personal data to third parties for commercial purposes. We share your data only in the following circumstances and only to the extent necessary for each purpose:

345jl engages contracted third-party service providers to assist with platform operations. These include identity verification service providers for KYC processing, payment processing partners (GCash, PayMaya, BPI, BDO, Metrobank), game providers whose certified systems are integrated into the 345jl platform, IT infrastructure and cloud hosting providers, customer support platform providers, and cybersecurity and fraud detection services. All third-party processors are bound by written data processing agreements that require them to process your data only on 345jl's documented instructions, to maintain adequate security standards, and to refrain from using your data for any independent purpose.

345jl is required by Philippine law to disclose personal data in certain circumstances, including: to PAGCOR in connection with regulatory audits, compliance reviews, or investigations; to the Anti-Money Laundering Council (AMLC) in connection with transaction monitoring, suspicious activity reporting, or freeze orders; to the National Privacy Commission in connection with data privacy investigations or incident notifications; and to any competent Philippine court, law enforcement agency, or other public authority in response to a valid legal order, subpoena, or warrant. 345jl will notify affected users of such disclosures to the extent permitted by applicable law and the terms of the legal order.

In the event that 345jl undergoes a merger, acquisition, sale of assets, or other corporate restructuring, personal data held by 345jl may be transferred to the successor entity as part of that transaction, subject to the same privacy protections described in this policy. You will be notified of any such transfer that materially affects the handling of your personal data before it occurs, to the extent practically possible.

345jl retains personal data for the minimum period necessary to fulfill the purpose for which it was collected, subject to the retention obligations imposed by Philippine law and PAGCOR regulations. The following retention periods apply:

Following the expiry of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be linked to you as an identifiable individual. Anonymized and aggregated data may be retained indefinitely for statistical and analytics purposes.

345jl implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• Encryption in transit: All data transmitted between your device and the 345jl platform is encrypted using TLS (Transport Layer Security) — the same standard used by Philippine banks and e-wallet providers including GCash and PayMaya.
• Encryption at rest: Sensitive personal data, including identity documents and financial information, is encrypted at rest using AES-256 encryption within our hosting infrastructure.
• Password security: Passwords are stored only in securely hashed form using a modern cryptographic hashing algorithm. 345jl staff cannot view or recover plain-text passwords under any circumstances.
• Access controls: Access to personal data is restricted to 345jl personnel who require it to perform their specific job functions. All staff with access to personal data are trained on data privacy obligations and are bound by confidentiality agreements.
• Multi-factor authentication: The 345jl account system uses OTP-based two-factor authentication for all logins from unrecognized devices to protect against unauthorized access even if login credentials are compromised.
• Regular security assessments: 345jl conducts periodic security assessments, penetration tests, and vulnerability scans of its platform infrastructure, consistent with PAGCOR technical security requirements.

In the event of a personal data breach that is likely to cause serious harm to you, 345jl will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay, in compliance with the requirements of the Philippine Data Privacy Act and NPC Circular No. 16-03.

345jl uses cookies and similar tracking technologies on the platform. A cookie is a small text file placed on your device by the 345jl server when you visit the platform. Cookies are used for the following purposes:

These cookies are essential for the platform to function and cannot be disabled without causing the platform to malfunction. They include session cookies that maintain your login state during an active session, security tokens used for CSRF (Cross-Site Request Forgery) protection, and load-balancing cookies that ensure your session is handled consistently across our server infrastructure. Strictly necessary cookies do not require your consent under applicable Philippine guidance.

Functional cookies remember your preferences on the platform, such as your preferred game category, language settings, and any display preferences you have configured in your account. These cookies are set for a defined duration and expire automatically. They improve your experience on the platform but are not essential for its basic operation.

345jl uses analytics data to understand how users navigate the platform, which features are used most frequently, and where technical issues may be occurring. Analytics data is collected in aggregated form and does not identify individual users. Analytics cookies may be declined through your browser settings or through the cookie preferences panel available on the 345jl platform.

You can manage cookie preferences through your browser settings, which typically allow you to block all cookies, block third-party cookies, or delete existing cookies. Note that blocking strictly necessary cookies will prevent the 345jl platform from functioning correctly and may make it impossible to log in or access your account.

As a data subject under Republic Act No. 10173, you have the following rights in relation to the personal data 345jl holds about you. To exercise any of these rights, contact our Data Privacy Officer at [email protected] with the subject line "Data Subject Rights Request."

• Right to be Informed: The right to be informed about the existence of processing of your personal data, the purposes, and your rights with respect to that data — fulfilled by this Privacy Policy.
• Right of Access: The right to obtain confirmation as to whether 345jl processes your personal data, and to receive a copy of the data held about you in a commonly used format within a reasonable timeframe.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. You can update many of your own account details directly within the platform; for changes to identity documentation, contact support.
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data where it is no longer necessary for the purpose collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been unlawfully processed. This right is subject to 345jl's legal and regulatory retention obligations, which may require us to retain certain data beyond your request.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Object: The right to object to processing based on legitimate interests, including the use of your data for direct marketing purposes. Objection to marketing can be exercised immediately through your account settings by updating your communication preferences.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe 345jl has processed your data in a manner that violates R.A. 10173. Details of the NPC's complaint process are available on the NPC's official website.

The 345jl platform is strictly for adults aged twenty-one (21) years or older, as required by PAGCOR for all casino-style online gaming in the Philippines. 345jl does not knowingly collect personal data from individuals under the age of 21.

If 345jl discovers that it has inadvertently collected personal data from an individual who is under 21 years of age, that data will be deleted immediately upon discovery and the associated account will be permanently closed. Any funds associated with the account will be returned via the original deposit method after verification of the refund destination, in compliance with PAGCOR regulations on underage gambling.

The primary data infrastructure supporting the 345jl platform is located within the Asia-Pacific region. Some of our third-party service providers — including certain game providers and technical infrastructure vendors — may process data from systems located outside the Philippines. Where such transfers occur, 345jl ensures that appropriate safeguards are in place consistent with the requirements of Section 21 of R.A. 10173.

Specifically, all cross-border transfers of personal data by 345jl or its processors are conducted only to jurisdictions that the National Privacy Commission considers to provide an adequate level of protection, or under contractual arrangements that impose data protection obligations equivalent to those required under Philippine law.

345jl reviews this Privacy Policy periodically and may update it to reflect changes in our data processing practices, changes in Philippine law or NPC guidance, or changes to the platform's features. Material changes to this policy will be communicated to registered users by email to their registered address and by prominent notice on the 345jl platform at least seven (7) calendar days before the updated policy takes effect, consistent with our notification obligations under R.A. 10173.

The effective date of the current version of this Privacy Policy is stated at the top of this document. Previous versions of this policy are available on request from the 345jl Data Privacy Officer. Continued use of the 345jl platform after the effective date of an updated policy constitutes acknowledgment of the updated terms.

For any inquiries, concerns, or requests relating to this Privacy Policy or to the personal data 345jl holds about you, please contact the 345jl Data Privacy Officer using the details below. All correspondence should be in English and should include your full name, registered email address, and a clear description of your inquiry or request.

If you are not satisfied with 345jl's response to a privacy-related inquiry or complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines, which is the independent supervisory authority responsible for enforcing R.A. 10173. Information about filing a complaint with the NPC is available through the NPC's official government channels.

For matters relating specifically to the 345jl gaming license, regulatory compliance, or disputes about gaming outcomes, the appropriate escalation route is to PAGCOR as described in the 345jl Terms & Conditions.