345jl Privacy Policy

345jl is committed to protecting the privacy and personal data of every player and visitor who interacts with our platform at 345jl.club ("the Platform"). This Privacy Policy ("Policy") describes how 345jl collects, uses, discloses, retains, and protects personal information in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, applicable issuances of the National Privacy Commission (NPC), and the data protection requirements imposed by the Philippine Amusement and Gaming Corporation (PAGCOR) as part of 345jl's licensing obligations.

By accessing the Platform, registering a 345jl account, or interacting with any of our services, you acknowledge that you have read and understood this Policy, and you consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of the Platform.

For the purposes of this Privacy Policy, 345jl acts as the personal information controller in respect of the personal data of players and users of the Platform. As personal information controller, 345jl determines the purposes and means by which personal data is processed.

345jl operates the Platform at 345jl.club under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR). Our operations are subject to PAGCOR's licensing conditions, which include specific requirements regarding player data collection, identity verification, and record retention for anti-money laundering (AML) and responsible gaming compliance purposes.

Questions or concerns about this Policy or 345jl's data processing practices may be directed to our Data Protection Officer (DPO) at the contact details provided in Section 15 of this Policy.

345jl collects personal data that is necessary and proportionate to the purposes described in this Policy. The categories of personal data we collect include:

3.1 Registration and Identity Data

• Full legal name;
• Date of birth (for mandatory 21+ age verification);
• Philippine mobile number;
• Email address;
• Username and encrypted password credentials;
• Government-issued ID type, number, and image (for KYC verification);
• Selfie photograph submitted for identity verification;
• Residential address.

3.2 Financial and Transaction Data

• GCash account number or Maya account number linked to your 345jl wallet;
• Bank account details (BPI, BDO, Metrobank) where used for deposits or withdrawals;
• Cryptocurrency wallet addresses (where applicable);
• Deposit history, withdrawal history, and transaction timestamps;
• Wallet balance and bonus credit records;
• Source of funds documentation where requested for AML compliance.

3.3 Gaming Activity Data

• Bet records, game session logs, win/loss history;
• Sports betting selections, odds accepted, and market types;
• Slot game activity including title, stake, and outcome data;
• Live casino session records;
• Bingo participation and jackpot records;
• Bonus utilization and wagering requirement progress.

3.4 Technical and Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser version;
• Session login and logout timestamps;
• Cookies and similar tracking technology data (see Section 10);
• Platform interaction logs for security and fraud detection purposes.

3.5 Communications Data

• Records of live chat conversations with 345jl support agents;
• Email correspondence and support ticket records;
• Complaint and dispute records;
• Responsible gaming communications and self-exclusion requests.

345jl collects personal data through the following channels and methods:

• Account registration: Data you provide when creating your 345jl account;
• KYC verification: Documents and images you upload to complete identity verification;
• Deposits and withdrawals: Payment information provided or confirmed when conducting financial transactions;
• Platform usage: Data generated automatically when you use the Platform, including gaming activity and technical logs;
• Customer support: Information you provide when contacting 345jl's support team via live chat or email;
• Cookies and analytics: Data collected automatically via cookies and similar tracking technologies as described in Section 10;
• Third-party verification providers: Identity verification data from licensed KYC and document verification service providers;
• Payment processors: Confirmation data from GCash, Maya, BPI, BDO, and other payment partners regarding transaction status.

345jl processes personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

345jl uses your personal data for the following purposes, which are directly connected to providing and improving the Platform and meeting our legal and regulatory obligations:

• Account management: Creating, maintaining, and managing your 345jl account, including processing the 345jl login and authentication;
• Service delivery: Processing bets, managing gaming sessions, crediting winnings, and operating all Platform features;
• Payments: Processing GCash, Maya, BPI, BDO, and other deposits and withdrawals;
• Identity verification: Completing KYC verification as required by PAGCOR and Philippine AML regulations;
• Age verification: Confirming that all players meet the mandatory 21+ age requirement;
• Fraud prevention and security: Detecting and preventing unauthorized account access, fraudulent transactions, and multi-accounting;
• AML compliance: Monitoring transactions for suspicious activity and meeting Suspicious Transaction Reporting (STR) obligations under Philippine AML law;
• Responsible gaming: Monitoring player activity to identify potential problem gambling behavior and enforcing deposit limits, self-exclusion periods, and other player protection measures;
• Customer support: Responding to your queries, complaints, and support requests;
• Communications: Sending transactional notifications (e.g., deposit confirmations, withdrawal updates, OTP codes) and, where you have opted in, promotional communications about 345jl offers;
• Analytics: Analyzing Platform usage patterns to improve game performance, user experience, and service quality;
• Legal and regulatory compliance: Meeting all obligations under applicable Philippine law and PAGCOR's licensing conditions.

345jl will not use your personal data for purposes incompatible with those listed above without first obtaining your consent, unless required to do so by law.

345jl does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 345jl shares personal data only in the following limited circumstances:

7.1 Service Providers and Processors

345jl engages trusted third-party service providers who process personal data on our behalf as personal information processors. These include:

• KYC and identity verification platform providers;
• Payment processors (GCash/Maya network operators, banking partners, cryptocurrency payment processors);
• Game software providers (JILI, PG Soft, Pragmatic Play, and others) — limited to the technical data necessary to operate games;
• IT infrastructure, cloud hosting, and security service providers;
• Customer support platform operators;
• Fraud detection and AML screening service providers.

All third-party processors engaged by 345jl are contractually bound to process personal data only in accordance with 345jl's instructions and to maintain security standards consistent with the Philippine Data Privacy Act.

7.2 Regulatory and Legal Disclosure

345jl may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other authorized Philippine government bodies in the following circumstances:

• Where required under PAGCOR's licensing conditions or a valid regulatory directive;
• In response to a valid court order, subpoena, or lawful order from a Philippine law enforcement authority;
• Where 345jl is obligated to file a Suspicious Transaction Report (STR) or Covered Transaction Report (CTR) under the Anti-Money Laundering Act;
• To protect the rights, property, or safety of 345jl, other players, or the public.

345jl 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 regulatory obligations. The general retention schedule is as follows:

Upon expiry of the applicable retention period, 345jl will securely delete or anonymize personal data, except where retention beyond these periods is required by a specific legal obligation or court order.

345jl implements technical, organizational, and physical security measures appropriate to the sensitivity of the personal data we process. These measures include:

• Encryption in transit: All data transmitted between your device and 345jl's servers is encrypted using industry-standard TLS (Transport Layer Security) protocols;
• Encryption at rest: Sensitive personal data, including KYC documents and financial records, is encrypted in storage;
• Password hashing: Account passwords are stored using one-way cryptographic hashing — plaintext passwords are never stored or accessible;
• Access controls: Access to personal data is restricted to 345jl personnel and authorized processors who require it to perform their duties, on a least-privilege basis;
• Two-factor authentication: 345jl's internal systems and player accounts support two-factor authentication to reduce unauthorized access risk;
• Security monitoring: Platform activity is monitored continuously for anomalies, unauthorized access attempts, and suspicious behavior;
• Penetration testing: 345jl's systems undergo periodic security assessments by qualified security professionals;
• Incident response: 345jl maintains a documented data breach response procedure. In the event of a personal data breach, 345jl will notify affected players and the National Privacy Commission as required by RA 10173 and NPC Circular 16-03.

Notwithstanding these measures, no online platform can guarantee absolute security. Players are encouraged to contribute to account security by using strong, unique passwords, enabling two-factor authentication, and promptly reporting any suspicious activity on their 345jl account.

345jl uses cookies and similar tracking technologies on the Platform to enable core functionality, improve performance, and understand how players interact with our services. The types of cookies used include:

• Strictly necessary cookies: Required for the Platform to function correctly, including session management and 345jl login state. These cannot be disabled without impairing core functionality.
• Functional cookies: Enable the Platform to remember your preferences such as language settings and device configuration to provide a personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data on how players use the Platform — page visits, session duration, and navigation paths — to help 345jl improve the service.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and suspicious login behavior.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the Platform. Disabling functional or analytics cookies will not prevent access but may affect your experience.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data processed by 345jl:

• Right to be informed: You have the right to be informed about how your personal data is collected and processed — which is the purpose of this Policy.
• Right of access: You may request a copy of the personal data 345jl holds about you, along with information about how it is processed.
• Right to rectification: You may request correction of inaccurate or incomplete personal data in your 345jl account records.
• Right to erasure: You may request deletion of your personal data where processing is no longer necessary, subject to overriding legal obligations (such as AML record retention requirements).
• Right to object: You may object to the processing of your personal data where such processing is based on legitimate interest or for direct marketing purposes.
• Right to data portability: Where technically feasible, you may request your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please submit a written request to 345jl's Data Protection Officer at the contact details provided in Section 15. 345jl will respond to data subject requests within thirty (30) days of receipt, in accordance with the timeframes prescribed under RA 10173 and NPC regulations.

The 345jl Platform is strictly prohibited for persons under 21 years of age in accordance with PAGCOR's licensing requirements and Philippine gambling regulations. 345jl does not knowingly collect personal data from persons under the age of 21.

If 345jl discovers or has reason to believe that an account has been registered by or on behalf of a person under 21 years of age, the account will be immediately suspended, all deposits will be returned to the originating payment source (less amounts already wagered), and the personal data associated with the account will be deleted to the extent permitted by law.

If you are a parent or guardian and believe that your minor child has registered a 345jl account, please contact our Data Protection Officer immediately at the details provided in Section 15. We will investigate and take appropriate action within five (5) business days.

The 345jl Platform operates primarily within the Philippines, and the majority of personal data processing occurs within Philippine territory. However, certain technical infrastructure components and third-party service providers engaged by 345jl may involve the storage or processing of personal data in data centers located outside the Philippines.

Where such cross-border transfers occur, 345jl ensures that adequate safeguards are in place to protect personal data at a standard equivalent to that required under the Philippine Data Privacy Act. These safeguards include:

• Contractual data processing agreements incorporating data protection clauses consistent with NPC requirements;
• Transfer to countries or processors that provide adequate levels of data protection as assessed by the NPC or 345jl's compliance team;
• Where required, obtaining specific consent from the data subject for cross-border transfer of sensitive personal information.

For further information about the specific countries to which your personal data may be transferred, please contact 345jl's Data Protection Officer.

345jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, 345jl will:

• Update the "Effective Date" and "Last Reviewed" dates at the top of this Policy;
• Post a notice on the Platform alerting players to the updated Policy;
• Where required by the nature of the change, send a notification to your registered email address.

Your continued use of the Platform after the publication of an updated Privacy Policy constitutes your acknowledgment of the revised Policy. If you do not agree to the changes, you should cease using the Platform and may close your account as described in the Terms and Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how 345jl protects your personal data.

For any questions, concerns, or requests relating to this Privacy Policy or 345jl's personal data processing practices, please contact our Data Protection Officer:

All data subject requests must be submitted in writing with sufficient information to verify your identity before we can process your request. 345jl support agents will never ask for your account password or OTP codes in any support communication.