635jl Privacy Policy

1. Introduction

635jl is committed to protecting the privacy and personal data of all players who use our online gaming platform. We understand that when you share your personal information with us, you're placing trust in 635jl — and we take that responsibility seriously.

This Policy applies to all personal data collected through the 635jl website at 635jl.net, our mobile-optimized platform, customer support channels, and any other services we provide. It covers data collected from registered players, prospective players, and visitors to our website.

635jl's data practices are governed by the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines. We are committed to full compliance with these regulations and to upholding the privacy rights of all Filipino players.

2. Data Controller

635jl acts as the data controller for all personal data collected through the 635jl platform. As data controller, 635jl determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data privacy laws.

635jl has appointed a Data Protection Officer (DPO) who is responsible for overseeing our data protection practices and serving as the point of contact for data privacy inquiries and requests. Contact details for our DPO are provided in Section 15 of this Policy.

3. Data We Collect

3.1 Registration Data

When you create a 635jl account, we collect the following personal data:

• Full legal name;
• Date of birth (to verify you are 21 years of age or older);
• Email address;
• Mobile phone number;
• Residential address (city, province, Philippines);
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

As required by Philippine anti-money laundering regulations and our licensing obligations, we collect the following KYC documentation:

• Government-issued photo ID (e.g., PhilSys National ID, passport, driver's license, SSS/GSIS ID, PRC ID, voter's ID);
• Proof of address (e.g., utility bill, bank statement, barangay certificate);
• Selfie or live photo for identity verification purposes;
• Additional documentation as required by our compliance team.

3.3 Financial Data

To process deposits and withdrawals, we collect:

• GCash or PayMaya account details (mobile number associated with the account);
• Bank account details for bank transfer transactions (account name, account number, bank name);
• Transaction history, including deposit amounts, withdrawal amounts, and timestamps.

635jl does not store full payment card numbers. All financial data is handled in accordance with applicable payment security standards.

3.4 Gaming Activity Data

We collect data about your gaming activity on the 635jl platform, including:

• Games played, wagers placed, and game outcomes;
• Session duration and frequency of play;
• Bonus usage and promotional participation;
• Responsible gaming tool usage (deposit limits, self-exclusion requests, etc.).

3.5 Technical and Device Data

When you access the 635jl platform, we automatically collect certain technical data, including:

• IP address and approximate geographic location;
• Device type, operating system, and browser type;
• Pages visited, time spent on pages, and navigation patterns;
• Cookie identifiers and session tokens (see Section 10).

3.6 Communications Data

When you contact 635jl's customer support team, we collect and retain records of those communications, including live chat transcripts, email correspondence, and any information you provide during support interactions.

4. How We Collect Your Data

635jl collects your personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make deposits or withdrawals, contact customer support, or participate in promotions;
• Automatically: Through cookies, web beacons, and similar tracking technologies when you access and use the 635jl platform (see Section 10);
• From third parties: From KYC verification service providers, payment processors, and fraud prevention services, where necessary to verify your identity or process transactions;
• From regulatory authorities: Where required by Philippine law or regulatory directive.

5. How We Use Your Data

635jl uses your personal data for the following purposes:

5.1 Account Management

To create and manage your 635jl account, verify your identity, process your transactions, and provide you with access to our games and services.

5.2 Regulatory Compliance

To comply with our obligations under Philippine gaming regulations, anti-money laundering laws (Republic Act No. 9160, as amended), and data privacy laws (Republic Act No. 10173). This includes conducting KYC verification, monitoring transactions for suspicious activity, and reporting to relevant authorities as required by law.

5.3 Payment Processing

To process deposits and withdrawals via GCash, PayMaya/Maya, and Philippine bank transfers, and to maintain accurate financial records of all transactions on your account.

5.4 Responsible Gaming

To monitor your gaming activity for signs of problem gambling, enforce responsible gaming tools you have activated (such as deposit limits or self-exclusion), and comply with our obligations to promote responsible gaming under Philippine regulations.

5.5 Customer Support

To respond to your inquiries, resolve disputes, and provide technical assistance. Support communications may be recorded and retained for quality assurance and training purposes.

5.6 Security and Fraud Prevention

To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, and other prohibited conduct on the 635jl platform. This includes automated monitoring of account activity and transaction patterns.

5.7 Platform Improvement

To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the 635jl platform. Where possible, this analysis is conducted using aggregated or anonymized data.

5.8 Marketing Communications

With your consent, to send you promotional offers, bonus notifications, and news about 635jl's games and services via email or SMS. You may withdraw your consent and opt out of marketing communications at any time through your account settings or by contacting our support team.

6. Legal Basis for Processing

635jl processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — i.e., to provide the 635jl gaming platform and associated services;
• Legal obligation: Processing required to comply with Philippine laws and regulations, including anti-money laundering laws, gaming regulations, and tax obligations;
• Legitimate interests: Processing necessary for 635jl's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights;
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

7.1 Service Providers

635jl shares personal data with trusted third-party service providers who assist us in operating the platform, subject to strict data processing agreements. These include:

• KYC and identity verification providers;
• Payment processors (GCash, Maya, and Philippine banking partners);
• Fraud detection and anti-money laundering screening services;
• Cloud hosting and infrastructure providers;
• Customer support platform providers.

All service providers are contractually required to process your data only as instructed by 635jl and to maintain appropriate security measures.

7.2 Regulatory and Legal Disclosure

635jl may disclose your personal data to Philippine government authorities, regulatory bodies, law enforcement agencies, or courts where required by law, court order, or regulatory directive. This includes disclosures to the Anti-Money Laundering Council (AMLC) and relevant gaming regulatory authorities.

7.3 No Sale of Personal Data

635jl does not sell, rent, lease, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes. Any sharing of data is limited to what is necessary to operate the platform and comply with applicable law.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 635jl's assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

8. Data Retention

635jl retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention periods:

• Account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by Philippine anti-money laundering regulations;
• KYC documentation: Retained for a minimum of five (5) years from the date of the last transaction, in accordance with Republic Act No. 9160;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Marketing consent records: Retained until you withdraw consent and for a reasonable period thereafter as evidence of consent.

When personal data is no longer required for any lawful purpose, 635jl will securely delete or anonymize it in accordance with our data retention and disposal procedures.

9. Data Security

635jl implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 635jl platform;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and responding to data breaches.

While 635jl takes all reasonable steps to protect your personal data, no security system is completely impenetrable. You are responsible for maintaining the security of your account credentials and for notifying 635jl immediately if you suspect unauthorized access to your account.

10. Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 635jl website. They help us recognize your device, remember your preferences, keep your session active, and analyze how you use our platform.

10.2 Types of Cookies We Use

• Essential cookies: Required for the platform to function correctly — including session management, login authentication, and security features. These cannot be disabled without affecting platform functionality;
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the 635jl platform, helping us identify areas for improvement;
• Preference cookies: Used to remember your settings and preferences, such as language and display options;
• Marketing cookies: Used, with your consent, to deliver relevant promotional content and measure the effectiveness of our marketing campaigns.

10.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 635jl platform. For detailed instructions on managing cookies in your browser, refer to your browser's help documentation.

11. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 635jl:

• Right to be informed: The right to be informed about how your personal data is collected, used, and processed — as set out in this Privacy Policy;
• Right of access: The right to request a copy of the personal data 635jl holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint: 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.

To exercise any of these rights, please contact 635jl's Data Protection Officer using the contact details in Section 15. We will respond to all valid requests within thirty (30) days. In complex cases, we may extend this period by a further thirty (30) days, with notice to you.

12. Children's Privacy

The 635jl platform is strictly restricted to individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. 635jl does not knowingly collect personal data from persons under 21 years of age.

If 635jl becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the 635jl platform, please contact our support team immediately.

13. Third-Party Links

The 635jl platform may contain links to third-party websites or services, such as payment provider portals. This Privacy Policy applies only to the 635jl platform and does not cover the data practices of any third-party websites. 635jl is not responsible for the privacy practices of third-party sites and encourages you to review the privacy policies of any third-party sites you visit.

14. Updates to This Policy

635jl 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. When material changes are made, we will notify registered players via email or a prominent notice on the 635jl platform, and update the "Last Updated" date at the top of this Policy.

Your continued use of the 635jl platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how 635jl protects your personal data.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or 635jl's data practices, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.