Privacy Policy — 32jl Casino

1.1 This Privacy Policy ("Policy") is issued by 32jl Casino ("32jl," "we," "us," or "our") and applies to all personal data collected from users of the 32jl.org website and all associated online services and gaming platforms operated under the 32jl brand.

1.2 32jl Casino is committed to protecting the privacy and personal data of all its registered players and site visitors, including Filipino players accessing the Platform from Metro Manila, Cebu, Davao, and all other regions of the Philippines. We process personal data in accordance with the requirements of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission (NPC).

1.3 By registering a 32jl account, making a deposit, or continuing to use the 32jl platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

1.4 This Policy should be read alongside 32jl's Terms & Conditions, which are incorporated by reference. In the event of any conflict between this Policy and the Terms & Conditions in respect of data privacy matters, the provisions of this Policy shall prevail.

2.1 The data controller responsible for personal data collected through the 32jl platform is 32jl Casino, operated at 32jl.org.

2.2 As data controller, 32jl determines the purposes for which your personal data is processed and the means by which it is processed. 32jl is responsible for ensuring that all personal data processing activities comply with the Philippine Data Privacy Act of 2012 and applicable NPC regulations.

2.3 Where 32jl engages third-party processors — such as payment service providers, game software providers, or identity verification services — those processors act only on 32jl's instructions and under contractual data processing agreements that impose equivalent or stricter data protection obligations.

2.4 Contact information for data privacy inquiries, including details for 32jl's designated Data Protection Officer (DPO), is provided in Section 15 of this Policy.

3.1 32jl collects personal data in the following categories from registered players and platform visitors:

3.2 32jl does not intentionally collect sensitive personal information as defined under the Philippine Data Privacy Act, except where necessary to comply with regulatory KYC obligations (such as capturing identity document photographs that may reveal ethnicity or religion incidentally). Where sensitive personal information is collected, it is processed with heightened security controls and access restrictions.

4.1 Directly from you. The majority of personal data 32jl holds is provided directly by you when you: create a 32jl account; submit KYC documentation; make a deposit or withdrawal request; contact 32jl's customer support team via live chat or email; complete account verification steps; or update your account profile settings.

4.2 Automatically through platform use. When you access 32jl.org or the gaming platform, technical data — including your IP address, device identifiers, browser type, and session information — is automatically collected through standard server logging and analytics technologies. This technical collection is inherent to the delivery of online services and does not require a specific action on your part.

4.3 Through cookies and similar technologies. 32jl uses cookies, web beacons, and similar tracking technologies to maintain session continuity, remember your login preferences, prevent fraud, and analyse platform usage patterns. A detailed explanation of how 32jl uses cookies is provided in Section 7 of this Policy.

4.4 From third-party verification services. As part of the KYC and anti-fraud process, 32jl may receive verification data from third-party identity verification service providers. This data supplements what you provide directly and is used solely for compliance purposes.

5.1 32jl processes your personal data for the following specified purposes:

• Account management and service delivery: To create, maintain, and manage your 32jl account; to process deposits and withdrawals through GCash, Maya, BDO, BPI, UnionBank, and other accepted Philippine payment methods; to provide access to games and sports betting services.
• Identity verification and KYC compliance: To verify your identity, age (minimum 21 years as required under PAGCOR guidelines), and payment method ownership in accordance with applicable Philippine gaming regulations and anti-money laundering obligations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account takeover attempts, money laundering, and any other activity prohibited under 32jl's Terms & Conditions or applicable Philippine law.
• Responsible gaming: To monitor gaming activity for indicators of problem gambling behaviour; to administer deposit limits, session reminders, cooling-off periods, and self-exclusion requests; to comply with PAGCOR responsible gaming requirements.
• Customer support: To respond to live chat inquiries, email support requests, and formal complaints; to maintain records of support interactions for quality assurance and dispute resolution purposes.
• Legal and regulatory compliance: To comply with applicable Philippine laws, PAGCOR regulations, Anti-Money Laundering Act (AMLA) obligations, and orders from competent regulatory authorities or courts.
• Marketing communications: To send promotional offers, bonus notifications, and gaming news to players who have opted in to receive such communications. Marketing emails can be unsubscribed from at any time via the unsubscribe link in each communication or by contacting 32jl support.
• Platform improvement: To analyse aggregated usage data — in anonymised and de-identified form — to improve platform features, game selection, and user experience for Filipino players.

6.1 32jl Casino does not sell your personal data to any third party. Data sharing is limited to the following specific categories of recipients, each of whom operates under contractual data protection obligations or statutory authority:

6.1.1 Payment Service Providers

When you deposit or withdraw funds using GCash, Maya, BDO, BPI, UnionBank, Metrobank, 7-Eleven (Cliqq), Coins.ph, or USDT TRC20, transaction data — including your registered name, amount, and account identifier — is shared with the relevant payment service provider for the sole purpose of processing the financial transaction. This sharing is necessary for the performance of your gaming services contract with 32jl.

6.1.2 Identity Verification Services

32jl engages licensed third-party KYC and identity verification service providers to assist with document authentication and identity validation. These providers receive KYC document data and identity information for the sole purpose of verification, under strict contractual data processing agreements.

6.1.3 Game Software Providers

Game providers — including WM Live, HRG Live, PG Soft, Jili, Pragmatic Play, and other licensed studios — receive a player session token and account identifier necessary to initiate and manage game sessions. These providers do not receive full registration data or financial account details. Game providers operate under their own licensing obligations and privacy standards.

6.1.4 Regulatory and Law Enforcement Authorities

32jl is legally required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities upon lawful demand. Such disclosures are made only to the extent required by law and are not within 32jl's discretion to decline.

6.1.5 Anti-Fraud and Security Services

Technical and behavioural data may be shared with anti-fraud platform providers for the purpose of detecting suspicious account activity. This sharing is based on 32jl's legitimate interest in preventing financial crime and protecting the integrity of the platform.

7.1 32jl.org uses cookies and similar technologies to maintain the functionality, security, and performance of the platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for platform operation, including session management, login authentication, and security token validation. These cookies cannot be disabled without rendering core platform functions inoperable.
• Functional Cookies: Used to remember your preferences, such as language settings, display preferences, and game filter selections, to provide a personalised experience across sessions.
• Analytics Cookies: Used to collect anonymised information about how players navigate and use the 32jl platform. This data is processed in aggregated, de-identified form to improve platform features and identify technical issues.
• Security and Anti-Fraud Cookies: Used to detect and prevent fraudulent login attempts, account takeover activity, and bot traffic. These cookies are a component of 32jl's security infrastructure.

7.2 32jl does not use third-party advertising cookies or cross-site tracking cookies that follow your browsing behaviour on external websites. All cookies set by 32jl are scoped to the 32jl.org domain.

7.3 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the 32jl platform. Disabling other cookie categories will not prevent you from accessing platform services but may reduce functionality or personalisation.

8.1 32jl retains personal data only for the period necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

8.2 Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with 32jl's data disposal procedures. Deletion is permanent and cannot be reversed.

9.1 32jl implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption: AES-256 encryption of data at rest; SSL/TLS 256-bit encryption of all data in transit between users and 32jl's servers.
• Access Controls: Role-based access control (RBAC) to personal data, with access granted only to 32jl personnel who require it for their specific job function. Access logs are maintained and reviewed regularly.
• Two-Factor Authentication (2FA): Available as a standard security feature for all 32jl accounts, providing an additional layer of protection beyond username and password credentials.
• Intrusion Detection: Network-level and application-level intrusion detection and prevention systems monitoring for anomalous access patterns and known attack signatures.
• Penetration Testing: Regular security assessments and penetration testing conducted by independent security professionals to identify and remediate vulnerabilities.
• Incident Response: A documented data breach response procedure, including notification obligations to affected players and the National Privacy Commission (NPC) in accordance with NPC Circular 16-03.

9.2 In the event of a personal data breach that poses a real risk to the rights and freedoms of affected players, 32jl will notify the NPC within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay through their registered email address.

10.1 As a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by 32jl Casino:

• Right to Be Informed: You have the right to be informed that your personal data is being processed, and the purposes and nature of that processing. This Privacy Policy fulfils 32jl's obligation to inform you.
• Right of Access: You have the right to obtain from 32jl a copy of the personal data we hold about you, together with information about how it is processed. Access requests will be fulfilled within fifteen (15) business days of receipt of a verified request.
• Right to Correction: You have the right to request correction of any inaccurate or incomplete personal data 32jl holds about you. Corrections to account registration data can be initiated through your account settings or by contacting 32jl support.
• Right to Erasure: In specified circumstances, you have the right to request deletion of your personal data. This right is subject to overriding legal obligations — for example, 32jl cannot delete financial transaction records during the period required under AMLA regulations, even upon request.
• Right to Object: You have the right to object to the processing of your personal data where that processing is based on legitimate interests rather than legal obligation. 32jl will assess such objections and respond within thirty (30) days.
• Right to Data Portability: You have the right to receive your personal data in a commonly used, machine-readable format, where technically feasible and where processing is carried out by automated means.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe 32jl has processed your personal data in violation of the Data Privacy Act. NPC contact details are available at privacy.gov.ph.

10.2 To exercise any of the rights described in this Section, please contact 32jl's Data Protection Officer using the contact details in Section 15. Requests must include sufficient information to verify your identity before 32jl can act on them. Identity verification is a necessary safeguard to prevent unauthorised access to another person's personal data.

11.1 32jl Casino is strictly prohibited from being accessed by persons under the age of twenty-one (21) years. This restriction is imposed by applicable Philippine gaming regulations and is enforced through mandatory KYC age verification for all registered accounts.

11.2 32jl does not knowingly collect personal data from persons under the age of 21. If 32jl discovers that a registered account belongs to a person under 21, the account will be immediately suspended, all processing of that person's data will cease, and the data will be securely deleted except to the extent required for regulatory reporting purposes.

11.3 32jl does not direct any marketing, promotional, or gaming-related communications toward persons under 21 years of age. All advertising and promotional materials used by 32jl are targeted exclusively at adults who meet the platform's minimum age requirement.

11.4 Parents and guardians are advised to implement parental control software on household devices to prevent minors from accessing online gaming platforms including 32jl. Detection of underage account access should be reported immediately to 32jl support.

12.1 The 32jl platform integrates services provided by third parties — including live casino game streams, slot game engines, payment gateways (GCash, Maya, bank transfer providers), and identity verification tools. These third-party service integrations are governed by contractual data processing agreements that impose data protection obligations consistent with this Privacy Policy.

12.2 Each third-party service provider integrated into the 32jl platform operates under their own privacy policies and is independently responsible for their data processing activities in relation to data shared with them under the circumstances described in Section 6 of this Policy. 32jl is not responsible for the privacy practices of third-party service providers beyond the contractual protections established in its processing agreements with them.

12.3 32jl.org may contain links to third-party websites for informational purposes. 32jl is not responsible for the content or privacy practices of any third-party website. Navigating away from 32jl.org to a third-party website means you are leaving 32jl's data protection scope, and your data on those sites is governed by the respective site's own privacy policy.

13.1 Where 32jl engages service providers whose data processing infrastructure is located outside the Philippines — for example, cloud hosting providers, game software platforms, or fraud detection services operating data centres in jurisdictions including Singapore, Hong Kong, or the European Union — personal data may be transferred across international borders as part of normal service delivery.

13.2 All international transfers of personal data by 32jl are governed by contractual safeguards and, where applicable, standard contractual clauses or equivalent mechanisms recognised under Philippine data protection law. 32jl does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate contractual safeguards.

13.3 In all cases, data transferred internationally by 32jl remains subject to the same use limitations, security standards, and retention requirements described in this Privacy Policy, regardless of where it is physically stored or processed.

14.1 32jl may update or revise this Privacy Policy from time to time to reflect changes in our data processing activities, applicable law, or regulatory requirements. The "Last Updated" date at the top of this Policy will always reflect the most recent version.

14.2 For material changes to this Policy — those that affect your rights, the purposes for which your data is processed, or the parties with whom it is shared — 32jl will provide advance notice to registered players via email and through in-platform notifications, with a minimum of seven (7) days' notice before the changes take effect.

14.3 Continued use of the 32jl platform following the effective date of any revision to this Privacy Policy constitutes acceptance of the updated Policy. If you do not agree with any revised terms, you may request voluntary account closure in accordance with Section 14.2 of the Terms & Conditions, and 32jl will process any outstanding balance to your verified payment method.

15.1 32jl Casino has designated a Data Protection Officer (DPO) as required under the Philippine Data Privacy Act of 2012. The DPO is responsible for overseeing compliance with data protection requirements and handling data subject rights requests.

15.2 To contact 32jl's Data Protection Officer, or to submit a data subject rights request, please use the following contact channels:

• Email: [email protected] — use the subject line "Data Privacy Request – [Your Username]" for all privacy-related inquiries.
• Live Chat: Available 24/7 on 32jl.org. Select "Account & Privacy" as the inquiry category for fastest routing to the appropriate team.

15.3 32jl acknowledges all data privacy inquiries within two (2) business hours and provides substantive responses within fifteen (15) business days for standard requests. Complex requests requiring legal review may take up to thirty (30) business days, with the extended timeline communicated upfront.

15.4 If you are unsatisfied with 32jl's handling of your data privacy inquiry, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC can be reached through their official government website.