Privacy Policy – 621jl Data Protection

1. Introduction

621jl is committed to protecting the privacy and personal data of all players who use our platform. This Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable guidelines issued by the National Privacy Commission of the Philippines.

This Policy applies to all personal data collected through the 621jl website, mobile applications, customer support channels, and any other touchpoints through which you interact with 621jl. It covers data collected both online and offline in connection with your use of the 621jl platform.

621jl acts as the personal information controller in respect of the personal data described in this Policy. Where 621jl engages third-party service providers to process personal data on its behalf, those providers act as personal information processors and are bound by contractual obligations consistent with this Policy.

2. Personal Data We Collect

621jl collects the following categories of personal data from players:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth and age verification information
• Residential address (including barangay, city, province, and postal code)
• Email address and mobile phone number
• Government-issued identification numbers (e.g., passport number, driver's license number, SSS/UMID number)

2.2 Financial Data

• GCash account details, PayMaya account details, or bank account information (BPI, BDO, Metrobank) used for deposits and withdrawals
• Transaction history, including deposit amounts, withdrawal amounts, and dates
• Account balance information

2.3 Gaming and Behavioral Data

• Betting history, game session data, and wagering patterns
• Login timestamps, session duration, and platform activity logs
• Responsible gaming preferences and self-exclusion status

2.4 Technical Data

• IP address and geolocation data
• Device type, operating system, and browser information
• Cookie identifiers and similar tracking data

2.5 Communications Data

• Records of communications with 621jl customer support
• Feedback, survey responses, and promotional opt-in preferences

3. How We Collect Your Data

621jl collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Data collected automatically when you use the platform, including through cookies, web beacons, server logs, and similar technologies.
• Third-party sources: Data received from identity verification providers, payment processors, fraud prevention services, and regulatory bodies where permitted by applicable law.

4. How We Use Your Personal Data

621jl uses the personal data we collect for the following purposes:

• To create, verify, and manage your 621jl player account
• To process deposits, withdrawals, and other financial transactions in Philippine Peso
• To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under Philippine law and PAGCOR regulations
• To verify your age and eligibility to use the platform (21 years of age or older)
• To provide customer support and respond to your inquiries
• To detect, investigate, and prevent fraud, cheating, and other prohibited activities
• To personalize your experience on the 621jl platform
• To send you promotional communications where you have opted in to receive them
• To administer responsible gaming tools, including deposit limits and self-exclusion
• To improve the 621jl platform through analytics and performance monitoring
• To comply with legal obligations and respond to lawful requests from regulatory authorities

5. Legal Basis for Processing

621jl processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the 621jl Terms & Conditions, including account management and transaction processing.
• Legal obligation: Processing required to comply with applicable Philippine law, PAGCOR regulations, AML obligations, and lawful orders from competent authorities.
• Legitimate interests: Processing for fraud prevention, platform security, and improvement of our services, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

621jl does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary:

6.1 Service Providers

Third-party vendors engaged by 621jl to provide services including payment processing (GCash, PayMaya, BPI, BDO, Metrobank), identity verification, fraud detection, cloud hosting, and customer support technology. These providers are contractually bound to process your data only on 621jl's instructions and in accordance with this Policy.

6.2 Regulatory and Law Enforcement Authorities

621jl may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities where required by law, court order, or regulatory directive.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 621jl's assets, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

7. Cookies and Tracking Technologies

621jl uses cookies and similar technologies to operate and improve the platform. The categories of cookies we use are:

• Essential cookies: Required for the platform to function correctly, including session management and security features. These cannot be disabled.
• Analytics cookies: Used to understand how players use the platform, which pages are visited most frequently, and where errors occur. This data is aggregated and anonymized.
• Preference cookies: Used to remember your settings and preferences, such as language and display options.
• Marketing cookies: Used to deliver relevant promotional content where you have consented to receive marketing communications from 621jl.

You can manage non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the 621jl platform.

8. Data Retention

621jl retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Marketing preference data is retained until you withdraw consent or close your account.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 621jl's data disposal procedures.

9. Data Security

621jl implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• TLS encryption for all data transmissions between your device and the 621jl platform
• Encryption of sensitive data at rest, including financial information and identification documents
• Access controls limiting personal data access to authorized 621jl personnel on a need-to-know basis
• Regular security assessments and penetration testing of platform infrastructure
• Incident response procedures for detecting, reporting, and managing personal data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 621jl will notify the National Privacy Commission and affected players in accordance with the requirements of the Philippine Data Privacy Act.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 621jl:

• Right to be informed: The right to be notified of how your personal data is collected and processed, as set out in this Policy.
• Right of access: The right to request a copy of the personal data 621jl holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to 621jl's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please contact the 621jl Data Protection Officer using the contact details provided in Section 14 of this Policy. 621jl will respond to all verified data subject requests within fifteen (15) business days of receipt.

11. Children's Privacy

The 621jl platform is strictly intended for adults aged 21 years and above. 621jl does 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 the minimum age requirement, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on the 621jl platform or provided personal data to us, please contact our support team immediately at the details provided in Section 14 so that we can take appropriate action.

12. Third-Party Links

The 621jl platform may contain links to third-party websites or services for informational purposes. 621jl is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Policy applies solely to personal data collected by 621jl through the 621jl platform.

13. Changes to This Privacy Policy

621jl 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, 621jl will provide advance notice to registered players via the platform or by email to the address on file.

The date of the most recent revision is indicated at the top of this Policy. We encourage you to review this Policy periodically to stay informed about how 621jl protects your personal data. Your continued use of the 621jl platform following any update constitutes your acceptance of the revised Policy.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 621jl, please contact our Data Protection Officer:

Email: [email protected]

621jl's Data Protection Officer is responsible for overseeing compliance with the Philippine Data Privacy Act and will handle all data subject requests and privacy-related inquiries. We aim to respond to all queries within fifteen (15) business days.

Please do not include sensitive personal information such as passwords, full payment card numbers, or government ID numbers in any email correspondence with 621jl.