3jlo Privacy Policy

1. Who We Are

This Privacy Policy applies to the 3jlo platform, accessible at https://3jlo.net, and all services, games, and features offered through it. When this policy refers to "3jlo," "we," "us," or "our," it means the operating entity behind the 3jlo platform.

3jlo is the data controller responsible for the personal information collected through this platform. We are committed to handling your data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC).

If you have any questions about this Privacy Policy or how 3jlo handles your personal data, please refer to the contact details in Section 15 of this document.

2. Personal Data We Collect

3jlo collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

We do not collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for KYC compliance and responsible gaming obligations. We do not collect biometric data beyond the selfie photograph required for identity verification.

3. How We Collect Your Data

3.1 Directly From You

The majority of personal data we hold is provided directly by you when you:

• Register for a 3jlo account and complete the sign-up form.
• Submit KYC documents for identity verification.
• Make a deposit or request a withdrawal.
• Contact our customer support team via email or live chat.
• Participate in promotions, surveys, or feedback requests.
• Update your account profile or communication preferences.

3.2 Automatically

When you access and use the 3jlo platform, we automatically collect certain technical and usage data through cookies, log files, and similar tracking technologies. This includes your IP address, device identifiers, browser information, and behavioral data about how you interact with the platform. See Section 7 for more details on cookies.

3.3 From Third Parties

In limited circumstances, 3jlo may receive personal data about you from third parties, including:

• Payment processors (e.g., GCash, PayMaya, banks) to confirm transaction details and verify payment method ownership.
• Identity verification service providers used to assist with KYC processing.
• Fraud prevention and AML screening services.
• Game providers, where game-level data is shared for dispute resolution purposes.

4. How We Use Your Personal Data

3jlo uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 3jlo account, including processing your registration, verifying your identity, and managing your account settings.
• Transaction Processing: To process deposits, withdrawals, and bonus credits, and to maintain accurate financial records of all transactions on your account.
• KYC & Regulatory Compliance: To verify your identity and age, comply with anti-money laundering (AML) obligations, and meet reporting requirements under applicable Philippine gaming and financial regulations.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce deposit and loss limits you have set, and administer self-exclusion requests.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, cheating, and other prohibited conduct.
• Platform Improvement: To analyze usage patterns, identify technical issues, and improve the features, performance, and user experience of the 3jlo platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your explicit consent to receive such communications. You may withdraw consent at any time.
• Legal Obligations: To comply with applicable laws, regulations, court orders, and requests from competent Philippine authorities.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 3jlo processes your personal data on the following lawful bases:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to when creating your 3jlo account — including account management, transaction processing, and customer support.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including AML regulations, gaming regulations, and tax reporting obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and analytics — where our legitimate interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have given your explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

6.1 We Do Not Sell Your Data

3jlo does not sell, rent, or trade your personal information to any third party for their own marketing or commercial purposes. Full stop.

6.2 Service Providers

We share personal data with carefully selected third-party service providers who assist us in operating the 3jlo platform. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law. Categories of service providers include:

• Payment processors (GCash, PayMaya, banks) for transaction processing.
• KYC and identity verification providers.
• Cloud hosting and infrastructure providers.
• Customer support platform providers.
• Analytics and platform performance monitoring tools.
• Game providers (for game-level data necessary for dispute resolution).

6.3 Regulatory & Legal Disclosure

3jlo may disclose your personal data to Philippine government authorities, regulatory bodies (including PAGCOR and the Anti-Money Laundering Council), law enforcement agencies, or courts where required by law, court order, or regulatory directive. We will notify you of such disclosures where legally permitted to do so.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 3jlo's business, 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 how your data is handled.

7. Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 3jlo platform. They help us recognize your browser, remember your preferences, keep your session active, and understand how you use our platform.

7.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that protect your account. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, game lobby layout, and responsible gaming limits you have configured.
• Analytics Cookies: Help us understand how players use the platform — which pages are visited most, where players encounter issues, and how we can improve the overall experience. Data collected is aggregated and anonymized where possible.
• Marketing Cookies: Used only with your explicit consent to deliver relevant promotional content and measure the effectiveness of our campaigns. You may opt out at any time.

7.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies may affect the functionality of the 3jlo platform, including your ability to stay logged in or access certain features. Disabling analytics or marketing cookies will not affect your ability to play.

8. Data Retention

3jlo retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Our general retention periods are as follows:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years after account closure, in compliance with AML record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later, as required by Philippine AML regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming Activity Logs: Retained for a minimum of three (3) years for dispute resolution and responsible gaming monitoring purposes.
• Customer Support Communications: Retained for two (2) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year after withdrawal of consent as evidence of prior consent.

When personal data is no longer required, 3jlo will securely delete or anonymize it in accordance with our internal data disposal procedures.

9. Data Security

3jlo implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the 3jlo platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized 3jlo personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Two-Factor Authentication: 3jlo supports and encourages the use of two-factor authentication (2FA) on player accounts to prevent unauthorized access.
• Penetration Testing: Our platform undergoes regular security assessments and penetration testing to identify and remediate vulnerabilities.
• Incident Response: 3jlo maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected players in accordance with RA 10173 requirements.

10. Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 3jlo:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and shared — which is the purpose of this Privacy Policy.
• Right to Access: You have the right to request a copy of the personal data 3jlo holds about you, along with information about how it is being processed.
• Right to Correction: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most account information directly through your account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations under AML and gaming regulations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests. We will honor such objections unless we have compelling legitimate grounds that override your interests.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
• Right to Lodge a Complaint: If you believe 3jlo has not handled your personal data in accordance with RA 10173, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 15. We will respond to all verified requests within thirty (30) days, or within the timeframe required by applicable law.

11. Children's Privacy

The 3jlo platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 3jlo does not knowingly collect personal data from persons under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data, and return any deposited funds to the source payment method after verification. If you believe a minor has registered on the 3jlo platform, please contact us immediately at the details provided in Section 15.

Parents and guardians are strongly encouraged to use parental control software to prevent minors from accessing online gaming platforms.

12. Cross-Border Data Transfers

In the course of operating the 3jlo platform, your personal data may be transferred to and processed in countries other than the Philippines — for example, where our cloud infrastructure providers or game providers are located. When such transfers occur, 3jlo ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law.

Safeguards for cross-border transfers may include contractual clauses that bind the recipient to data protection standards consistent with RA 10173, or transfers to jurisdictions that the National Privacy Commission has recognized as providing adequate data protection.

By using the 3jlo platform, you acknowledge and consent to the transfer of your personal data to other countries as described in this section, subject to the safeguards described above.

13. Third-Party Links

The 3jlo platform may contain references to third-party services such as payment processors (GCash, PayMaya, banks) and game providers. While 3jlo takes care in selecting its partners, we are not responsible for the privacy practices of third-party services. Each third-party service operates under its own privacy policy, and we encourage you to review those policies before providing personal data to any third party.

This Privacy Policy applies solely to personal data collected and processed by 3jlo through the 3jlo platform at https://3jlo.net.

14. Updates to This Privacy Policy

3jlo reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via the email address associated with their account and/or by posting a prominent notice on the 3jlo platform prior to the changes taking effect.

The "Last updated" date at the top of this page reflects the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how 3jlo protects your personal data. Your continued use of the platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by 3jlo, please contact our Data Protection Officer (DPO):

For general support inquiries unrelated to data privacy, please use the main support contact: [email protected]

For complaints that have not been resolved to your satisfaction, you may contact the National Privacy Commission of the Philippines through their official channels.

For responsible gaming support, self-exclusion requests, or problem gambling resources, please visit the 3jlo Responsible Gaming page.