345jl Casino — Privacy Policy

1. Introduction

This Privacy Policy (the "Policy") describes how 345jl (hereinafter "345jl", "we", "us", or "the Company") collects, uses, stores, discloses, and otherwise processes personal data belonging to individuals who use the 345jl online casino and sportsbook platform accessible at 345jl.cam (the "Platform"), including registered Account Holders and visitors who browse the Platform without creating an account.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines (the "DPA"), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC). It should be read alongside the 345jl Terms and Conditions, which govern the overall use of the Platform.

By accessing the Platform, creating an Account, or otherwise providing your personal data to 345jl, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein, to the extent that such processing is based on your consent. Where processing is based on a different legal ground (legal obligation, legitimate interest, or contractual necessity), your consent is not required but you are still entitled to be informed, as provided in this Policy.

2. Data Controller

For purposes of the Data Privacy Act of 2012, the personal information controller responsible for your personal data is the 345jl operating entity, a PAGCOR-licensed gaming operator conducting business through the Platform at 345jl.cam.

345jl has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the DPA and this Policy. You may contact the DPO for any privacy-related inquiry, rights request, or complaint by writing to [email protected] with the subject line "Data Privacy — DPO Request". Contact details for the DPO are also available in Section 14 of this Policy.

3. Personal Data We Collect

345jl collects the following categories of personal data, depending on the nature of your interaction with the Platform:

345jl does not intentionally collect special categories of sensitive personal data as defined under the DPA (such as health data, religious beliefs, or political affiliations) except where a player voluntarily provides such information — for example, when requesting a responsible gaming accommodation related to a health condition. Such data is treated with heightened protection and strict access controls.

4. How We Collect Your Data

345jl collects personal data through the following channels:

• Direct collection: Data you provide when registering an Account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in a promotion;
• Automated collection: Technical and gaming data collected automatically through cookies, log files, and platform analytics tools as you navigate and use the Platform;
• Third-party sources: Identity verification data returned by KYC verification service providers; payment data returned by payment processors (GCash, Maya, BPI, BDO, etc.); fraud risk signals from third-party risk intelligence providers;
• Regulatory sources: Where required by PAGCOR or Philippine law enforcement authorities, information may be exchanged with regulatory bodies in the exercise of their lawful functions.

5. Purpose & Legal Basis of Processing

345jl processes your personal data only for specified, explicit, and legitimate purposes. The following table summarises our primary processing purposes and the corresponding legal basis under the DPA:

• Account registration and management — Legal basis: Performance of contract (your use of the Platform).
• Identity verification (KYC) and age verification — Legal basis: Legal obligation (PAGCOR licensing conditions, Republic Act No. 9160 AMLA as amended).
• Processing deposits and withdrawals — Legal basis: Performance of contract.
• Anti-money laundering (AML) monitoring and fraud prevention — Legal basis: Legal obligation (RA 9160 and PAGCOR conditions); Legitimate interest of 345jl and its players.
• Providing customer support — Legal basis: Performance of contract; Legitimate interest.
• Responsible gaming monitoring and intervention — Legal basis: Legal obligation (PAGCOR responsible gaming framework); Legitimate interest (player welfare).
• Sending promotional communications and bonus offers — Legal basis: Consent (opt-in marketing preferences). Withdrawal of consent does not affect other processing activities.
• Platform security, fraud detection, and abuse prevention — Legal basis: Legitimate interest of 345jl and its players.
• Compliance with PAGCOR reporting and audit requirements — Legal basis: Legal obligation.
• Statistical analysis and platform improvement — Legal basis: Legitimate interest (pseudonymised or aggregated data only wherever possible).

6. Sharing Your Personal Data

345jl does not sell, rent, or trade your personal data to any third party. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Service providers and processors: Companies that provide services to 345jl under data processing agreements, including KYC verification providers, payment processors (GCash, Maya, BPI, BDO, Metrobank, UnionBank, and others), game software providers, customer support platform operators, cloud hosting providers, and fraud prevention services. All processors are contractually required to maintain confidentiality and apply appropriate technical and organizational security measures.
• PAGCOR and Philippine regulatory authorities: 345jl is legally obligated to submit certain player data, transaction records, and compliance reports to PAGCOR as a condition of its license. Requests from other Philippine government bodies (AMLC, NBI, PNP, etc.) are honored where accompanied by appropriate legal authority.
• Group companies: 345jl may share data within its affiliated group of companies for internal operational purposes (shared IT infrastructure, compliance functions, group-level anti-money laundering programs). All group entities are bound by equivalent data protection standards.
• Business transfers: In the event of a merger, acquisition, or sale of assets involving 345jl, player data may be transferred to the acquiring entity as part of that transaction. Affected players will be notified prior to any such transfer.
• With your explicit consent: In any other circumstance not described above, 345jl will seek your prior explicit consent before sharing your personal data.

7. Data Retention

345jl retains personal data for as long as is necessary to fulfill the purpose for which it was collected, subject to minimum retention periods mandated by applicable Philippine law. The following retention periods apply as a general guide:

• Account and identity data: Retained for the duration of the Account plus a minimum of five (5) years following Account closure, in compliance with PAGCOR licensing requirements and RA 9160 AMLA record-keeping obligations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by PAGCOR and the AMLC;
• Gaming and session data: Retained for three (3) years following the relevant session or gaming activity;
• Customer support communications: Retained for two (2) years from the date of the communication, or longer if the communication relates to an active dispute;
• Marketing preference records: Retained for the duration of the Account plus one (1) year following Account closure.

Upon expiry of the applicable retention period, personal data is securely deleted, anonymised, or pseudonymised in a manner that prevents re-identification. Where data must be retained beyond these periods due to legal proceedings, regulatory investigation, or dispute resolution, it will be flagged and retained under heightened access controls until the relevant matter is resolved.

8. Data Security

345jl implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption applied to all data in transit between your device and 345jl's servers;
• Encryption at rest for sensitive personal data and financial records stored in 345jl's databases;
• Strict role-based access controls limiting staff access to personal data on a need-to-know basis;
• Multi-factor authentication required for all internal administrative systems;
• Regular third-party security penetration testing and vulnerability assessments;
• Comprehensive employee data protection training aligned with NPC-issued guidelines;
• Incident response and data breach notification procedures aligned with the DPA's 72-hour NPC notification requirement.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 345jl will notify the NPC within 72 hours of becoming aware of the breach and will notify affected data subjects without undue delay, in accordance with NPC Circular No. 16-03 on Personal Data Breach Management.

9. Cookies & Tracking Technologies

The 345jl Platform uses cookies and similar tracking technologies to operate and improve the Platform experience. The following categories of cookies are in use:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. They cannot be disabled without preventing you from using the Platform.
• Functional Cookies: Store your preferences such as language settings, responsible gaming tool configurations, and game lobby display preferences to improve your experience on return visits.
• Analytics Cookies: Collect anonymised or pseudonymised data about how players navigate the Platform — which pages are visited most, where users exit, and how features are used. This data informs platform improvements and is never used to identify individuals.
• Marketing Cookies: Used only where you have consented to marketing communications. These cookies help 345jl deliver relevant promotional content based on your Platform activity.

You can manage cookie preferences through your browser settings at any time. Disabling non-essential cookies will not prevent you from accessing or using the Platform, although some functional preferences may not be saved between sessions.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 345jl:

To exercise any of these rights, submit a written request to 345jl's Data Protection Officer using the contact details in Section 14. 345jl will acknowledge your request within three (3) business days and aim to resolve it within fifteen (15) business days, extendable by a further fifteen (15) days where the complexity of the request requires it. We may need to verify your identity before processing a rights request to prevent unauthorized access to another person's data.

11. Minors & Age Policy

The 345jl Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in compliance with PAGCOR regulations governing online gaming in the Philippines. 345jl does not knowingly collect personal data from individuals under the age of 21.

If 345jl discovers or receives credible information that personal data has been collected from a person under the age of 21, the following actions will be taken immediately:

• The Account will be permanently suspended;
• All personal data associated with the Account will be flagged and secured;
• The matter will be reported to PAGCOR in accordance with licensing conditions;
• Personal data will be deleted in compliance with the DPA and PAGCOR guidelines as soon as regulatory and legal obligations permit.

Parents, guardians, or other concerned parties who believe a minor has registered on the 345jl Platform should contact support immediately via live chat or at [email protected] for immediate action.

12. Cross-Border Data Transfers

Some of 345jl's service providers — including certain game software providers, cloud infrastructure operators, and KYC verification vendors — may process personal data in countries outside the Philippines. Where such international data transfers occur, 345jl ensures that an adequate level of data protection is maintained through one or more of the following mechanisms:

• The recipient country has been recognized by the NPC as providing an adequate level of protection;
• Standard contractual clauses approved by the NPC are in place with the data importer;
• The transfer is necessary for the performance of a contract with you (e.g., processing a payment through an international payment network);
• You have provided explicit consent to the transfer after being informed of the risks.

You may request information about the specific safeguards applicable to any international transfer of your personal data by contacting the 345jl DPO.

13. Changes to This Privacy Policy

345jl reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, applicable law, NPC guidance, or PAGCOR regulatory requirements. Material changes will be communicated to registered Account Holders by email to their registered address and/or through a prominent notice on the Platform at least seven (7) days before the amended Policy takes effect.

The "Last Updated" date at the top of this Policy indicates when the most recent version was published. We encourage you to review this Policy periodically. Your continued use of the Platform following notification of material changes constitutes your acknowledgment of the updated Policy. Where changes require fresh consent under the DPA, 345jl will seek that consent separately before proceeding with the relevant processing activity.

14. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 345jl, please contact our Data Protection Officer (DPO) through the following channels. The DPO is independent in the exercise of their privacy compliance functions and is directly accessible to all data subjects:

• Subject Line: "Data Privacy — DPO Request" (required for routing to the DPO team)
• Email: [email protected]
• Live Chat: Available 24/7 on the Platform — request to be escalated to the DPO team
• Response Commitment: Acknowledgement within 3 business days; resolution within 15 business days

If you are not satisfied with 345jl's response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) through the NPC's official channels. The NPC is the Philippine government authority responsible for enforcing the Data Privacy Act of 2012.