jl39 respects your right to privacy. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173).
Philippine Data Privacy Act Compliance: This Privacy Policy is issued in compliance with Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. By registering and using jl39, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.
jl39 ("jl39," "we," "us," "our") operates the online gaming platform accessible at jl39.one and acts as the Personal Information Controller (PIC) as defined under the Philippine Data Privacy Act of 2012. As PIC, jl39 determines the purposes and means by which your personal data are processed.
jl39 operates under PAGCOR oversight, and all personal data processing activities are conducted in accordance with applicable Philippine gaming regulations, the Data Privacy Act, and PAGCOR's data governance requirements for licensed operators.
For all data privacy inquiries, contact our Data Protection Officer (DPO) using the details provided in Section 13 of this Policy.
jl39 collects personal data from you in the following categories, depending on how you interact with the platform:
jl39 does not collect or process sensitive personal information (as defined by the Data Privacy Act) beyond what is strictly necessary for identity verification and anti-money laundering compliance.
| Purpose | Data Categories Used |
|---|---|
| Account creation and authentication | Registration data, technical data |
| Identity verification (KYC) per PAGCOR requirements | KYC data, registration data |
| Processing deposits, withdrawals, and game transactions | Financial data, registration data |
| Anti-money laundering (AML) monitoring and reporting | Financial data, KYC data, technical data |
| Fraud detection and platform security | Technical data, financial data, communications data |
| Responsible gaming monitoring and enforcement of deposit limits | Financial data, usage data, registration data |
| Customer support and dispute resolution | Communications data, registration data, financial data |
| Regulatory reporting to PAGCOR | Registration data, KYC data, financial data |
| Sending promotional communications (where consent given) | Registration data, usage data |
| Platform performance analytics and product improvement | Technical data, usage data (anonymized where possible) |
jl39 does not use automated profiling to make decisions that produce significant legal effects on individual Players without human review.
jl39 processes your personal data on the following lawful bases as recognized under the Philippine Data Privacy Act:
jl39 does not sell, rent, or trade your personal data to any third party for their own marketing purposes. Your data is shared only in the following circumstances:
jl39 is required by Philippine law to share data with PAGCOR and other relevant government bodies (including the Anti-Money Laundering Council — AMLC) where mandated by licensing conditions, court order, or lawful government request.
Transaction data is shared with payment service providers (GCash / Maya, BDO, BPI, Metrobank, and USDT processing partners) to the minimum extent necessary to process your deposits and withdrawals. These providers process data under their own privacy policies and are bound by data sharing agreements with jl39.
KYC documentation is processed by jl39's third-party identity verification service provider. This provider operates under a data processing agreement with jl39 and is prohibited from using your data for any purpose other than verification.
Limited technical data (such as Player ID and session tokens) is passed to game providers (JILI Games, Evolution, Pragmatic Play, PG Soft) to enable game delivery. Game providers do not receive your personally identifiable information beyond what is technically necessary.
In the event of a merger, acquisition, or sale of all or part of jl39's business, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and any change in data controller via email or in-platform notification in advance.
jl39 uses cookies and similar tracking technologies to ensure the platform functions correctly, to maintain your login session, and to understand how Players use jl39 for product improvement purposes.
| Cookie Type | Purpose | Duration |
|---|---|---|
| Essential / Session | Maintain your login session and platform functionality. jl39 cannot operate without these. | Session |
| Security | CSRF protection, bot detection, and fraud prevention signals. | Session / 24 hrs |
| Analytics | Anonymized usage data to understand how Players navigate jl39 and improve the platform. | Up to 12 months |
| Preferences | Remember your language settings, display preferences, and responsible gaming configurations. | Up to 12 months |
You may configure your browser to block or delete cookies. Note that disabling essential cookies will impair jl39's core functionality, including login session management.
jl39 retains your personal data for the following periods:
Upon the expiry of applicable retention periods, jl39 will securely delete or irreversibly anonymize your personal data.
jl39 implements technical and organizational security measures appropriate to the risks associated with processing your personal data, including:
In the event of a personal data breach that poses a risk to your rights and freedoms, jl39 will notify affected Players and the NPC within the timeframes prescribed by the Data Privacy Act and its Implementing Rules.
As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl39:
To exercise any of these rights, contact jl39's DPO using the details in Section 13. You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.
21+ Age Restriction: jl39 strictly prohibits use of the platform by any person under 21 years of age, as required by Philippine gaming law. jl39 does not knowingly collect personal data from individuals under 21 years old. KYC verification is mandatory for all accounts and is specifically designed to verify that the account holder meets the minimum age requirement. Any account found to be held by a person under 21 years of age will be immediately terminated and all associated data will be deleted, except where retention is required by law.
If you are a parent or guardian and believe that your child under 21 has created a jl39 account, please contact our DPO immediately at the contact details provided in Section 13. We will investigate and take appropriate action without undue delay.
Some of jl39's third-party service providers — including certain game providers and cloud infrastructure partners — may process data outside of the Philippines. Where cross-border data transfers occur, jl39 ensures that:
jl39 maintains a register of all cross-border data transfers as required by the NPC's data governance framework.
jl39 may update this Privacy Policy from time to time to reflect changes in our data processing activities, applicable law, or PAGCOR requirements. Material changes will be communicated to registered Players via email or in-platform notification at least 7 days before the revised Policy takes effect.
The date of the most recent revision is displayed at the top of this page. Your continued use of jl39 after the effective date of a revised Policy constitutes your acceptance of the changes. If you do not agree to a revised Policy, you must close your jl39 account prior to the effective date.
For all data privacy questions, access requests, corrections, or complaints relating to jl39's processing of your personal data, please contact our Data Protection Officer:
If you are not satisfied with jl39's response to your data privacy complaint, you have the right to escalate to the National Privacy Commission (NPC) of the Philippines.
Six practical commitments that back up our Privacy Policy with real actions.
Every connection between your device and jl39 is protected by 256-bit SSL encryption — the same standard used by Philippine banks. Your personal and financial data cannot be intercepted in transit.
jl39 processes all personal data in compliance with Republic Act No. 10173 and is registered with the National Privacy Commission of the Philippines. Your rights as a data subject are fully recognized.
jl39 never sells, rents, or trades your personal data to third parties for marketing purposes — ever. Your data is used exclusively to deliver and improve the jl39 platform and to comply with Philippine legal requirements.
Your jl39 account password is stored using industry-standard cryptographic hashing. Even jl39's own systems cannot retrieve your plaintext password — only you know it.
New device logins to jl39 require SMS OTP verification sent to your registered Philippine mobile number — an extra layer of protection that ensures only you can access your account from an unrecognized device.
jl39 has a designated Data Protection Officer available to handle access requests, corrections, and complaints. All data privacy requests receive a response within 2 business days.
Play with confidence knowing your data is secure, your identity is protected, and your rights under Philippine law are fully respected at jl39. Must be 21+.
21+ PAGCOR regulated. For Filipino players only. Play responsibly.