739jl Casino Privacy Policy

1 Introduction

739jl Casino ("739jl," "we," "our," or "us") is committed to protecting the privacy and personal data of every player and visitor who interacts with our Platform. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have over your own data under Philippine law.

This policy is drafted in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and relevant issuances from the National Privacy Commission (NPC) of the Philippines. It also reflects applicable requirements under the Anti-Money Laundering Act of 2001 (Republic Act No. 9160, as amended) and PAGCOR's player data governance requirements applicable to licensed online gaming operators.

We review and update this Privacy Policy periodically. Material changes will be communicated to registered players by email and announced on the Platform. The "Last Updated" date at the top of this page reflects the most recent revision.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, 739jl Casino is the Personal Information Controller (PIC) in respect of the personal data you provide to us or that we collect in connection with your use of the Platform. As PIC, 739jl determines the purposes and means of processing your personal data and bears responsibility for ensuring that processing is conducted lawfully and in accordance with this Privacy Policy.

A designated Data Protection Officer (DPO) has been appointed by 739jl in accordance with NPC Advisory No. 2017-01. The DPO oversees the Platform's data protection program, handles data subject requests, and serves as the primary point of contact with the National Privacy Commission. You may contact the DPO using the details provided in Section 14 of this policy.

3 Personal Data We Collect

739jl collects personal data through several channels: directly from you during registration and account management, automatically through your use of the Platform, and in limited cases from third-party verification and payment service providers. The categories of personal data we collect are set out in the table below.

4 How We Use Your Personal Data

739jl uses your personal data only for the purposes for which it was collected, or for compatible purposes that you would reasonably expect. The primary purposes of our data processing activities are:

4.1 Account Management and Service Delivery

To create and maintain your 739jl account, verify your identity, process your deposits and withdrawals in Philippine pesos, deliver the games and betting services you request, and communicate account-related information such as transaction confirmations and security alerts.

4.2 Legal and Regulatory Compliance

To fulfill our obligations under Philippine law, including KYC verification required by the Anti-Money Laundering Act, age verification required by PAGCOR licensing conditions, suspicious transaction monitoring and reporting to the Anti-Money Laundering Council (AMLC), and tax documentation as required by the Bureau of Internal Revenue (BIR).

4.3 Fraud Prevention and Platform Security

To detect and prevent fraud, money laundering, account takeover, bonus abuse, and other prohibited conduct identified in the 739jl Terms & Conditions. This includes automated and manual review of unusual account activity and transactions.

4.4 Customer Support

To respond to your inquiries, resolve disputes, process complaints, and provide assistance in both English and Tagalog through our 24/7 support team.

4.5 Platform Improvement

To analyze aggregated and anonymized usage data to improve Platform performance, user experience, game selection, and customer support quality. Individual player data is anonymized before being used for analytical purposes.

4.6 Marketing Communications (With Consent)

To send you promotional offers, bonus announcements, and personalized recommendations — but only where you have given specific, informed consent during registration or through your account settings. You may withdraw this consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, 739jl processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and 739jl — i.e., to operate your account, process transactions, and deliver gaming services;
• Legal obligation: Processing required to comply with Philippine law, including AML, KYC, PAGCOR licensing, and tax obligations;
• Legitimate interests: Processing necessary for 739jl's legitimate interests in fraud prevention, platform security, and improving services, where those interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications, where you have given clear and informed consent that you may withdraw at any time.

6 Sharing of Personal Data

739jl does not sell your personal data. We share personal data only in the following limited circumstances, and only to the extent necessary for the specified purpose:

6.1 Payment Service Providers

When you make a deposit or withdrawal, your relevant financial details are shared with GCash, PayMaya, BPI, BDO, Metrobank, or UnionBank as applicable. These providers act as independent data processors and are subject to their own privacy policies and Philippine Bangko Sentral ng Pilipinas (BSP) data governance requirements.

6.2 Identity Verification Services

To fulfill KYC obligations, 739jl may engage third-party identity verification services accredited under Philippine AML regulations. These services process your government ID and biometric data for verification purposes only and are contractually prohibited from using your data for any other purpose.

6.3 Regulatory and Law Enforcement Authorities

739jl will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government authorities when required to do so by law, court order, or valid regulatory directive. 739jl will, where legally permitted, notify affected players of such disclosure.

6.4 Service Providers Under Data Processing Agreements

739jl engages certain third-party service providers (such as cloud hosting, analytics, and customer support technology providers) who process personal data on our behalf. All such providers are engaged under written Data Processing Agreements that require them to process data only on 739jl's documented instructions and to implement appropriate technical and organizational security measures.

7 Cookies and Tracking Technologies

739jl uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use are as follows:

• Strictly necessary cookies: Required for the Platform to function. These include session cookies that keep you logged in as you navigate between pages. You cannot opt out of these without losing core Platform functionality;
• Performance and analytics cookies: Collect anonymized data about how players use the Platform, which pages are most visited, and where errors occur. Used to improve site performance and user experience;
• Functionality cookies: Remember your preferences such as display language and responsible gaming limit settings, so you don't need to re-enter them on every visit;
• Security cookies: Support fraud detection and account security monitoring by detecting unusual login patterns or session activity.

You can manage cookie preferences through your browser settings. Note that disabling non-essential cookies will not affect your ability to access and use 739jl's core gaming features, though some convenience features may not function as expected.

8 Data Retention Periods

739jl retains your personal data for as long as your account is active, and for a defined period after account closure as required by Philippine law. The following retention periods apply:

• KYC and identity documents: Retained for a minimum of five (5) years after the end of the business relationship, in compliance with Section 9 of the Anti-Money Laundering Act as amended by RA 10365;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AML record-keeping requirements;
• Account data and correspondence: Retained for the duration of account activity plus three (3) years following account closure, to support dispute resolution and regulatory inquiry;
• Marketing consent records: Retained for the period during which you have given consent, plus a reasonable period thereafter as evidence of consent status;
• Technical logs: Typically retained for ninety (90) days for operational and security monitoring purposes, then deleted or anonymized.

Upon expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymized so that it can no longer be associated with any individual.

9 Security Measures

739jl implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Key security controls include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 739jl's servers;
• Encryption at rest for all databases containing personal and financial data;
• Role-based access controls limiting internal data access to personnel with a specific operational need;
• Multi-factor authentication requirements for all 739jl staff accounts with access to player data systems;
• Regular third-party penetration testing and vulnerability assessments of the Platform and supporting infrastructure;
• 24/7 security monitoring and automated anomaly detection systems;
• Annual security awareness training for all staff handling personal data;
• An incident response plan aligned with NPC Circular 16-03 breach notification requirements.

While 739jl employs industry-standard security practices, no system is completely impenetrable. We encourage players to use a unique, strong password for their 739jl account and to enable two-factor authentication where available.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of personal data that 739jl holds about you. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. We will respond to all valid requests within fifteen (15) calendar days of receipt.

11 Minors and Age Restriction

The 739jl Platform is strictly for individuals who are at least twenty-one (21) years of age. We do not knowingly collect personal data from persons under 21. If we discover that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the data in question, and report the matter to the relevant PAGCOR authority in accordance with our licensing obligations.

Parents and guardians who believe that a minor in their care has registered with 739jl are urged to contact our support team immediately via live chat. We will prioritize the investigation and closure of any underage account. The child's personal data will be deleted as swiftly as AML record-keeping requirements permit.

12 Cross-Border Data Transfers

Some of the third-party service providers engaged by 739jl (such as cloud infrastructure providers) may process or store data in data centres located outside the Philippines. Where such cross-border transfers occur, 739jl ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under RA 10173.

These safeguards include contractual clauses in Data Processing Agreements that bind the recipient to compliance with Philippine data protection standards, and 739jl's assessment that the recipient country's data protection regime provides an adequate level of protection. 739jl does not transfer personal data to jurisdictions that do not meet these standards.

13 Changes to This Privacy Policy

739jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements from PAGCOR or the National Privacy Commission. When material changes are made, we will notify registered players by email to the address on file and display a prominent notice on the Platform for at least thirty (30) days following the update.

Minor changes that do not materially affect your rights or our core data practices may be made without individual notification, though the "Last Updated" date at the top of this page will always be revised to reflect the current version. We encourage you to review this Privacy Policy periodically to stay informed of how 739jl protects your data.

Your continued use of the 739jl Platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the revised policy, please contact support to request account closure in accordance with the 739jl Terms & Conditions.

14 Contact Us / Data Protection Officer

For any questions, requests, or concerns related to this Privacy Policy or the personal data that 739jl holds about you, please contact our Data Protection Officer. All data subject requests will be acknowledged within three (3) business days and fully responded to within fifteen (15) calendar days as required under RA 10173.

If you are not satisfied with our response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. The NPC can be reached through its official website and handles complaints from data subjects regarding violations of RA 10173 by personal information controllers operating in the Philippines.