23jl Casino – Privacy Policy

1. Data Controller

23jl is the data controller responsible for the personal information processed in connection with the 23jl platform and its services. As data controller, 23jl determines the purposes and means of processing your personal data and is accountable for ensuring that processing is carried out in compliance with the Data Privacy Act of 2012 (RA 10173) and the rules and regulations issued thereunder by the National Privacy Commission of the Philippines.

23jl has designated a Data Protection Officer (DPO) as required under RA 10173. Queries, requests, and complaints relating to the processing of your personal data may be directed to the DPO using the contact details set out in Section 14 of this Policy.

2. Personal Data We Collect

23jl collects the following categories of personal data in connection with account registration, platform use, and regulatory compliance:

23jl does not collect or store full payment card numbers. If card payment is offered in future, such data will be handled by a PCI-DSS compliant payment processor and will not be stored on 23jl systems.

3. How We Collect Your Data

23jl collects your personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or completing any other form or process on the 23jl platform.
• Automated Technical Collection: Data collected automatically through your browser or device when you access the platform, including IP addresses, device identifiers, session data, and cookies (see Section 7).
• Third-Party Payment Processors: Transaction confirmation data from GCash, Maya, BPI, BDO, Metrobank, and other integrated payment providers, confirming the fact and amount of payments made to or from your 23jl wallet.
• Identity Verification Providers: Results of identity and document verification checks performed by 23jl's KYC service providers on the government-issued ID documents you submit.
• Regulatory Sources: Where required by law, 23jl may receive information from PAGCOR, law enforcement agencies, or other competent government bodies in the Philippines.

4. Purposes of Processing

23jl processes your personal data for the following purposes:

• Creating, maintaining, and managing your 23jl account and player profile.
• Processing deposits and withdrawals and maintaining accurate transaction records in PHP.
• Verifying your identity and age (21+) as required by PAGCOR regulations and anti-money laundering (AML) obligations under Republic Act No. 9160, as amended.
• Delivering the games, betting markets, live casino, and other platform services you access.
• Providing customer support and responding to your inquiries and complaints.
• Detecting, investigating, and preventing fraud, cheating, money laundering, and other prohibited conduct.
• Personalizing your platform experience and making relevant game and promotion recommendations.
• Sending transactional communications (deposit confirmations, withdrawal notifications, security alerts) and, with your consent, promotional communications about 23jl offers.
• Complying with legal and regulatory obligations applicable to 23jl's operations, including PAGCOR reporting requirements.
• Monitoring responsible gaming indicators and intervening where necessary to protect player welfare, including through the enforcement of self-exclusion and cooling-off periods.
• Analyzing aggregated, anonymized usage data to improve the platform's performance and user experience.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 23jl relies on the following legal bases for processing personal data:

• Contract Performance: Processing necessary to fulfill the agreement between you and 23jl — account management, game delivery, payment processing, and customer support.
• Legal Obligation: Processing required to comply with applicable Philippine laws and PAGCOR regulations, including AML/CFT obligations, KYC requirements, and tax reporting.
• Legitimate Interest: Processing carried out for 23jl's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights.
• Consent: Processing for marketing communications and certain cookies, where your consent is obtained and can be withdrawn at any time.

6. Data Sharing and Disclosure

23jl does not sell, rent, or trade your personal data. We may share your information with the following categories of recipients only to the extent necessary for the stated purpose:

• PAGCOR and Philippine Regulatory Authorities: As required by law, including in response to official regulatory inquiries, audits, and mandatory reporting requirements.
• Philippine Law Enforcement and Courts: Where 23jl is legally required to disclose information in response to a valid legal process, court order, or investigation by a competent Philippine authority.
• Identity Verification and KYC Providers: Third-party providers engaged to verify the identity documents you submit as part of the KYC process. These providers are bound by confidentiality and data processing agreements.
• Payment Processing Partners: GCash, Maya, and banking partners receive the minimum data required to process your transaction. 23jl does not share full financial account details beyond what payment routing requires.
• Game Content Providers: Third-party game studios and live dealer providers may receive session identifiers necessary to authenticate your gameplay. These providers are subject to data processing agreements.
• Platform Infrastructure Providers: Cloud hosting, content delivery, and cybersecurity providers that support the operation of the 23jl platform, all bound by data processing agreements consistent with RA 10173.

All third-party data processors engaged by 23jl are required to maintain the confidentiality and security of your personal data and to process it only for the specific purposes for which it has been shared.

7. Cookies and Tracking Technologies

23jl uses cookies and similar tracking technologies on its platform. Cookies are small data files stored on your device that allow the platform to recognize you between sessions, maintain your login state, and improve your experience.

The categories of cookies used by 23jl include:

• Strictly Necessary Cookies: Required for the platform to function correctly. These include session authentication tokens, security cookies, and load-balancing cookies. They cannot be disabled without affecting core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and "Remember Me" login state.
• Analytics Cookies: Collect aggregated, anonymized data about how players use the platform to help 23jl improve its services. Used with your consent.
• Marketing Cookies: Used only with your explicit consent to track your interactions with 23jl promotions and measure campaign effectiveness.

You may control your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log in and use the 23jl platform.

8. Data Retention

23jl retains your personal data for as long as your account is active and for a defined period after account closure, in accordance with the following principles:

• Active Account Data: Retained for the duration of your account's existence to support account management, dispute resolution, and regulatory compliance.
• Financial Transaction Records: Retained for a minimum of five (5) years after the transaction date, consistent with Philippine AML record-keeping requirements under AMLA and BSP regulations.
• KYC and Identity Documents: Retained for five (5) years from the date of submission or from account closure, whichever is later, as required by PAGCOR and AML regulations.
• Support and Communication Records: Retained for three (3) years from the date of the communication for quality assurance and dispute resolution purposes.
• Self-Exclusion Records: Retained indefinitely to prevent re-registration during an active self-exclusion period and to maintain a record of the exclusion history.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized so that it can no longer be linked to an identifiable individual.

9. Data Security

23jl implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS/HTTPS) encryption for all data in transit between your device and 23jl's servers.
• Encryption at rest for sensitive data stored in 23jl's databases.
• One-way cryptographic hashing of all account passwords — 23jl staff cannot view your plaintext password.
• Role-based access controls limiting employee access to personal data to those with a specific need to access it in connection with their job function.
• Regular security vulnerability assessments and penetration testing of the platform.
• Intrusion detection and anomaly monitoring systems.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 23jl will notify the National Privacy Commission (NPC) and affected players in accordance with the breach notification requirements under RA 10173 and NPC Circular No. 16-03.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, as a data subject you have the following rights with respect to your personal data held by 23jl:

To exercise any of these rights, please contact 23jl's Data Protection Officer using the contact details in Section 14. 23jl will respond to all verified requests within 15 business days. We may request proof of identity before processing a data subject request. If you are not satisfied with 23jl's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

11. Minors and Age Restriction

The 23jl platform is strictly restricted to persons aged 21 years or older. 23jl does not knowingly collect personal data from persons under the age of 21. Account registration requires submission of a valid Philippine government-issued ID confirming the applicant's date of birth, and accounts are verified against this minimum age requirement before activation.

If 23jl discovers that personal data has been collected from an individual under the age of 21, the relevant account will be immediately closed, all associated data will be deleted (subject to any overriding legal obligation to retain specific records), and any funds will be returned to the depositing payment method after appropriate verification.

If you are a parent or guardian and believe that a minor has registered with 23jl, please contact our Data Protection Officer immediately using the details in Section 14.

12. International Data Transfers

23jl's primary data processing infrastructure is located within or affiliated with the Philippines. In circumstances where personal data must be transferred to a recipient outside the Philippines — for example, to a game content provider or infrastructure vendor operating in another country — such transfers will only be made where:

• The recipient country or organization provides an adequate level of data protection as recognized under applicable Philippine standards; or
• Appropriate contractual safeguards are in place with the receiving party, including data processing agreements consistent with RA 10173 requirements; or
• The transfer is necessary for the performance of the contract between you and 23jl (e.g., routing a transaction through an international payment network).

13. Changes to This Privacy Policy

23jl reserves the right to update or amend this Privacy Policy at any time. Any material changes will be posted on the 23jl platform with an updated "Last Updated" date. Where changes are significant, 23jl will provide prior notice to registered players via email or an in-platform notification before the revised policy takes effect.

Your continued use of the 23jl platform following the effective date of any amended Privacy Policy constitutes your acknowledgment of the revised policy. We encourage you to review this page periodically to remain informed of how 23jl protects your data.

14. Contact and Data Protection Officer

For all privacy-related inquiries, data subject rights requests, or complaints regarding 23jl's handling of your personal data, please contact the 23jl Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe that 23jl has failed to comply with its obligations under RA 10173.