3jla Privacy Policy

This Privacy Policy ("Policy") describes how 3jla ("we", "us", "our", "the Company"), operator of the online gaming platform at https://3jla.club, collects, processes, stores, shares, and protects the personal data of individuals ("you", "your", "the Player") who access or use our platform, services, and any associated communications.

This Policy applies to all personal data processed by 3jla in connection with:

• Account registration, verification, and management;
• Deposits, withdrawals, and all financial transactions conducted on 3jla;
• Gameplay activity across all categories including slots, live casino, sports betting, bingo, and fishing games;
• Customer support interactions conducted via live chat, email, or any other channel;
• Marketing and promotional communications where you have consented;
• Visits to the 3jla website, including passive data collected through cookies and analytics.

3jla operates under authorisation from the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations issued by the National Privacy Commission (NPC).

3jla collects personal data that is necessary and proportionate to the purposes for which it is collected. The following categories of data are processed:

3jla does not intentionally collect sensitive personal information (as defined under the Philippine Data Privacy Act) beyond what is strictly required for identity verification and PAGCOR compliance. Where such data is required, it is handled with heightened protection measures.

Personal data is collected by 3jla through the following means:

• Direct Provision. Information you provide directly when registering an account, completing identity verification, making deposits or withdrawals, completing responsible gaming questionnaires, or contacting customer support.
• Automated Collection. Technical and behavioural data collected automatically when you visit or use the 3jla platform, including through cookies, web beacons, log files, and analytics technologies.
• Third-Party Sources. Identity and fraud risk information received from KYC/AML verification service providers, PAGCOR's self-exclusion register, payment processor confirmation data, and fraud prevention databases — where 3jla is legally or contractually authorised to receive such information.
• Inferred Data. Data derived from analysis of information you have provided or that has been collected automatically — for example, responsible gaming risk indicators generated from your gameplay patterns.

3jla processes your personal data for the following specific, legitimate, and declared purposes:

• Account Creation & Management: To register your account, verify your identity and age, maintain your player profile, and administer your use of the platform.
• Transaction Processing: To process GCash, Maya, bank, and other deposits and withdrawals; maintain accurate financial records; and facilitate the reconciliation of your account balance.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, Philippine AML obligations under Republic Act No. 9160 as amended, and FATF standards — including transaction monitoring, suspicious activity reporting, and record-keeping.
• Customer Support: To respond to your inquiries, resolve disputes, and maintain support records for quality assurance and audit purposes.
• Responsible Gaming: To detect patterns associated with problem gambling, enforce self-exclusion requests, implement deposit limits and session controls, and comply with PAGCOR's responsible gaming framework.
• Platform Security & Fraud Prevention: To detect and prevent fraud, account takeover, bonus abuse, collusion, and other prohibited conduct described in the Terms and Conditions.
• Platform Improvement: To analyse usage patterns and improve the 3jla user experience, product offerings, and technical infrastructure.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided explicit consent. You may withdraw consent at any time.

Under the Philippine Data Privacy Act and its implementing rules, 3jla relies on the following lawful bases for processing your personal data:

• Contractual Necessity. Processing required to fulfil the contract between you and 3jla as set out in the Terms and Conditions — including account administration, payment processing, and gameplay facilitation.
• Legal Obligation. Processing required to comply with PAGCOR licensing conditions, the Philippine AML Act, the Data Privacy Act itself, and any other applicable Philippine law or regulatory direction.
• Legitimate Interests. Processing undertaken in 3jla's legitimate interests where those interests are not overridden by your rights — including fraud detection, platform security, abuse prevention, and service improvement activities.
• Consent. Processing based on your freely given, specific, informed, and unambiguous consent — primarily in the context of marketing communications and optional analytics. You have the right to withdraw consent at any time without prejudice to prior processing.

3jla does not sell, rent, or trade your personal data. We share your data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Processors. GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), BDO, BPI, Metrobank, GrabPay, and other payment service providers — to facilitate deposits and withdrawals. Each processor handles your payment data under their own privacy policies and applicable Philippine financial regulations.
• Identity Verification Providers. Third-party KYC and AML compliance providers engaged by 3jla to perform age verification, identity document validation, and sanctions screening as required by PAGCOR and Philippine AML law.
• Technology & Infrastructure Partners. Cloud hosting providers, cybersecurity firms, and game software providers (e.g., JILI Games, Evolution Gaming, PG Soft) who process data on our behalf under data processing agreements. These providers are prohibited from using your data for their own purposes.
• PAGCOR & Regulatory Authorities. The Philippine Amusement and Gaming Corporation, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies — where disclosure is required by law, court order, or valid regulatory demand.
• Professional Advisors. Legal counsel, auditors, and compliance consultants bound by professional confidentiality obligations where such disclosure is necessary to protect 3jla's legal rights or comply with its obligations.

3jla uses cookies and similar tracking technologies to operate the platform, maintain your session, prevent fraud, and improve the user experience. A cookie is a small text file placed on your device when you visit the 3jla website.

The following types of cookies are used on 3jla:

• Strictly Necessary Cookies. Required for the platform to function. These include session authentication tokens, CSRF protection tokens, and load balancing cookies. These cannot be disabled without preventing you from using the platform.
• Functional Cookies. Enable personalisation features such as remembered language preferences, game lobby filters, and display settings. Disabling these will not prevent access but may reduce convenience.
• Analytics Cookies. Used to understand how players interact with the platform — which games are most played, which pages have high exit rates, and where technical issues occur. This data is aggregated and anonymised where possible. Analytics cookies require your consent.
• Security Cookies. Used for fraud detection, bot prevention, and account takeover prevention. These are essential to platform security.

You may manage cookie preferences through your browser settings. Note that disabling certain cookies may affect platform functionality. Instructions for cookie management are available in your browser's help documentation.

3jla 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. The following retention periods apply:

• Account Data & Identity Verification Records: Retained for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and the Philippine AML Act's record-keeping obligations.
• Transaction Records (deposits, withdrawals, wager history): Retained for five (5) years following the date of each transaction, in accordance with AML record-keeping requirements.
• Customer Support Records: Retained for three (3) years following resolution of the relevant interaction, unless related to a dispute that requires longer retention.
• Marketing Consent Records: Retained for the duration of your account plus two (2) years following consent withdrawal, to demonstrate compliance with consent requirements.
• Technical & Log Data: Retained for twelve (12) months from the date of collection, or longer where required for security investigations.
• Self-Exclusion Records: Retained indefinitely to prevent re-registration in breach of self-exclusion, unless a time-limited exclusion period has expired and the player has formally applied to have it lifted.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised such that it can no longer be linked to an identifiable individual.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 3jla:

• Right to Be Informed. The right to be informed about how your personal data is collected, used, retained, and disclosed — as set out in this Policy.
• Right of Access. The right to request confirmation of whether 3jla holds personal data about you and, if so, to receive a copy of that data in a commonly used electronic format.
• Right to Rectification. The right to request correction of inaccurate or incomplete personal data. Note that certain identity data cannot be altered after verification without supporting documentation.
• Right to Erasure. The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. This right is subject to limitations where retention is required by law (e.g., AML record-keeping).
• Right to Data Portability. The right to receive your personal data in a structured, commonly used, machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Object. The right to object to processing of your personal data for direct marketing purposes. Upon receipt of an objection, 3jla will cease such processing immediately.
• Right to Lodge a Complaint. The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

3jla implements a multi-layered technical and organisational security framework to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Key security measures include:

• Encryption in Transit: All data transmitted between your device and 3jla's servers is protected using TLS 1.2 or higher with 256-bit AES encryption.
• Encryption at Rest: Sensitive personal data and financial records stored on 3jla's servers are encrypted using industry-standard at-rest encryption.
• Access Controls: Role-based access control ensures that 3jla employees can only access the personal data categories that are necessary for their specific job function. All access is logged and subject to periodic audit.
• Two-Factor Authentication: 3jla's internal administrative systems require multi-factor authentication. Players are strongly encouraged to enable 2FA on their accounts.
• Penetration Testing: 3jla conducts regular vulnerability assessments and penetration testing of its platform infrastructure to identify and remediate security weaknesses.
• Incident Response: A documented data breach response procedure is maintained, with defined escalation paths to the Data Protection Officer, executive management, and the NPC as required.

Notwithstanding these measures, no electronic transmission or storage system is entirely immune to security risk. Players are responsible for maintaining the confidentiality of their own account credentials and should report any suspected unauthorised access to 3jla support immediately.

If 3jla discovers that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete all personal data associated with that account, and void any transactions that may have taken place. Winnings generated by an under-age account will be withheld and any deposits refunded subject to verification.

If you believe that a minor has registered on 3jla, please contact our support team immediately at [email protected]. We will treat such reports as a priority and investigate within 24 hours.

Parents and guardians are encouraged to use parental control software to restrict access to online gambling platforms on shared or family devices.

The 3jla platform integrates with third-party game providers, payment processors, and analytics services. While 3jla takes care to engage only reputable service providers and implements data processing agreements with all third parties who process personal data on our behalf, 3jla cannot be responsible for the privacy practices of independent third-party sites or services that you access independently outside the 3jla platform.

Game providers such as JILI Games, Evolution Gaming, PG Soft, Pragmatic Play, and others may process technical session data necessary for game delivery. This processing is governed by data processing agreements between 3jla and each provider and is limited to what is necessary for the technical delivery of the game. Game providers are not permitted to use player data for their own commercial purposes.

Some of the third-party service providers engaged by 3jla may be located outside the Philippines. Where personal data is transferred to a jurisdiction that does not offer an equivalent level of data protection to the Philippines, 3jla implements appropriate safeguards including:

• Standard contractual clauses approved by the National Privacy Commission or equivalent international standards;
• Binding corporate rules where applicable within corporate group structures;
• Adequacy assessments to confirm the receiving jurisdiction's data protection standards;
• Data processing agreements that impose obligations on the recipient equivalent to those applicable under Philippine law.

By using the 3jla platform, you acknowledge and consent to the transfer of your personal data to service providers outside the Philippines where such transfers are conducted under the safeguards described above.

3jla reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, 3jla will notify registered players via the platform or their registered email address with at least seven calendar days' advance notice.

The "Effective Date" at the top of this Policy reflects the date of the most recent version. We encourage you to review this Policy periodically. Continued use of the 3jla platform following notification of any amendment constitutes your acceptance of the updated Policy. If you do not accept the updated Policy, you must cease using the platform and contact support to close your account.

The most current version of this Policy will always be accessible at https://3jla.club/privacy-policy.

3jla has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and the Philippine Data Privacy Act. The DPO serves as the primary point of contact for all data protection matters and NPC communications.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 3jla, you may contact us through the following channels:

• Live Chat: Available 24/7 via the 3jla platform — average response under 2 minutes.
• Support Email: [email protected] — please mark data protection inquiries with the subject line "Data Privacy Request".