635jl Privacy Policy

1 Overview & Scope

This Privacy Policy (the "Policy") describes how 635jl (the "Platform," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals who access or use 635jl.org and its associated services (collectively, the "Services").

This Policy applies to all registered 635jl account holders, website visitors, and anyone who interacts with the 635jl platform in any capacity — whether through a desktop browser, mobile browser, or any other device. It governs personal data collected through the 635jl website, account registration process, gaming activity, financial transactions, customer support interactions, and any other touchpoint between you and the platform.

635jl is committed to protecting the personal data of Filipino players in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations as overseen by the National Privacy Commission (NPC) of the Philippines. Where applicable, 635jl also observes the data handling requirements of PAGCOR and other relevant regulatory bodies.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection regulations, 635jl acts as the personal information controller (PIC) in respect of the personal data collected from users of the platform.

As the personal information controller, 635jl determines the purposes for which your personal data is processed, the means of processing, and the policies and safeguards applicable to that processing. Where 635jl engages third-party service providers to assist with specific processing activities (such as payment processing or game delivery), those providers act as personal information processors and are contractually bound to process your data only on 635jl's documented instructions and in compliance with applicable data protection law.

635jl has appointed a designated Data Protection Officer (DPO) responsible for overseeing data protection compliance across the platform. Contact details for the DPO are provided in Section 13 of this Policy.

3 Personal Data We Collect

635jl collects personal data from you directly when you register an account, use our services, or contact support, and indirectly through automated technical means as you interact with the platform. The categories of personal data we collect are described below.

3.1 Data You Provide Directly

3.2 Data Collected Automatically

4 How We Use Your Personal Data

635jl processes your personal data for the following purposes:

• Account Registration & Management: To create and administer your 635jl account, verify your identity and age, and maintain accurate records of your profile and preferences.
• Service Delivery: To provide access to games, process bets, calculate and credit winnings, and deliver all features of the 635jl platform to you.
• Financial Transactions: To process deposits, withdrawals, and bonus credits; to verify payment methods; and to maintain accurate transaction records in compliance with financial regulations.
• Anti-Money Laundering (AML) & Compliance: To monitor transactions for suspicious activity, conduct customer due diligence (CDD), and comply with obligations under Philippine AML laws and PAGCOR regulatory requirements.
• Responsible Gaming: To monitor betting patterns for signs of problematic gambling, enforce self-exclusion orders and deposit limits, and provide appropriate responsible gaming interventions.
• Customer Support: To respond to your inquiries, resolve disputes, and handle complaints in a timely and effective manner.
• Security & Fraud Prevention: To detect, investigate, and prevent unauthorized account access, fraud, collusion, bonus abuse, and other prohibited conduct.
• Platform Improvement: To analyze usage data and player feedback in order to improve the design, performance, and game offering of the 635jl platform.
• Marketing Communications: Where you have provided consent, to send you promotional offers, bonus notifications, and platform updates via SMS or email. You may withdraw consent at any time.
• Legal Compliance: To comply with applicable laws, regulations, court orders, and requests from competent Philippine regulatory and law enforcement authorities.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, all processing of personal data must be grounded in a recognized legal basis. 635jl processes your personal data on the following lawful bases:

• Contractual Necessity: Processing required to perform the contract between you and 635jl — including account creation, game access, and payment processing — is lawful as it is necessary to fulfill our obligations to you.
• Legal Obligation: Processing required to comply with applicable laws, including AML regulations, PAGCOR requirements, tax obligations, and other mandatory regulatory requirements applicable to online gaming platforms in the Philippines.
• Legitimate Interests: Processing carried out for fraud prevention, security monitoring, platform improvement, and responsible gaming purposes, where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where processing is based on your consent — such as marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

635jl does not sell, rent, or trade your personal data to third parties for commercial purposes. Your data may be shared with the following categories of recipients only to the extent necessary to fulfill the purposes described in Section 4:

• Payment Service Providers: GCash (Mynt – Globe Fintech Innovations), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, UnionBank, and other Philippine payment partners — for the purpose of processing deposits and withdrawals.
• Game Content Providers: Licensed gaming studios such as JILI Technology, Evolution Gaming, Pragmatic Play, PG Soft, and SA Gaming — limited to the technical data necessary to deliver their games within the 635jl platform. These providers do not receive your financial or identity data.
• Identity Verification Services: Third-party KYC providers engaged to verify your identity and age during account registration and ongoing compliance checks.
• Technology Infrastructure Providers: Cloud hosting and content delivery providers who store and transmit platform data under strict data processing agreements.
• Regulatory & Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities — where disclosure is required by law, court order, or regulatory direction.
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to binding confidentiality obligations.

7 Data Retention

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

• Account Data: Retained for the duration of your account's active status, plus a minimum of five (5) years after account closure, as required by Philippine AML and financial record-keeping obligations.
• Transaction Data: Deposit, withdrawal, and betting records are retained for a minimum of five (5) years from the date of the transaction, in line with PAGCOR regulatory requirements and Philippine tax law.
• KYC & Identity Documents: Retained for the duration of the account relationship plus five (5) years after closure, or longer if required by specific regulatory obligations applicable at the time of closure.
• Customer Support Records: Chat and email correspondence is retained for three (3) years from the date of the last interaction, for dispute resolution and quality management purposes.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications, after which it is deleted or anonymized within thirty (30) days.
• Anonymized Usage Data: Aggregated, anonymized platform analytics data may be retained indefinitely as it no longer constitutes personal data.

When retention periods expire, personal data is securely deleted or irreversibly anonymized in accordance with 635jl's data disposal procedures.

8 Security Measures

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

• Encryption in Transit: All data transmitted between your device and the 635jl platform is encrypted using TLS 1.2 or higher with 256-bit SSL certificates, equivalent to the encryption standard used by major Philippine banks including BPI and BDO.
• Encryption at Rest: Sensitive personal data stored on 635jl servers — including financial account details and identity documents — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. Staff access is governed by role-based permissions, and all access events are logged and audited.
• Multi-Factor Authentication: Administrative access to systems holding personal data requires multi-factor authentication. Players are encouraged to enable two-factor authentication (2FA) on their 635jl accounts for additional protection.
• Penetration Testing: The 635jl platform undergoes regular security assessments and penetration testing by independent cybersecurity professionals.
• Incident Response: 635jl maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, you will be notified in accordance with the timelines required by the Data Privacy Act and the NPC's breach notification guidelines.

9 Cookies & Tracking Technologies

635jl uses cookies and similar tracking technologies (such as web beacons and local storage tokens) to operate and improve the platform. Cookies are small text files placed on your device that allow us to recognize you and remember your preferences across sessions.

The categories of cookies used by 635jl are as follows:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication tokens that keep you logged in during your gaming session and security cookies that protect against fraudulent requests. These cookies cannot be disabled without rendering the platform unusable.
• Functional Cookies: Used to remember your preferences — such as language settings, preferred payment method, and lobby display configuration — to provide a more personalized experience on return visits.
• Analytical Cookies: Used to collect aggregated data about how players use the 635jl platform, including which pages are visited most frequently and where users encounter difficulty. This data is used solely to improve platform performance and user experience.
• Marketing Cookies: Where you have provided consent, used to deliver relevant promotional content and measure the effectiveness of 635jl marketing campaigns. Marketing cookies are only activated with your explicit consent.

You may manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will impact your ability to use the 635jl platform. Disabling functional or analytical cookies will not prevent access but may reduce the quality of your experience.

10 Your Rights Under Philippine Data Privacy Law

Under Republic Act No. 10173 (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 whether your personal data is being, has been, or will be processed, and the specific purposes for which it is processed.
• Right to Access: The right to request a copy of the personal data 635jl holds about you, along with information about how it is being used, the categories of recipients with whom it has been shared, and the retention period.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by 635jl. You may update most profile information directly from your account settings.
• Right to Erasure / Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, where consent has been withdrawn, or where it has been unlawfully processed — subject to 635jl's legitimate legal and regulatory retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or for purposes based on 635jl's legitimate interests. Where you object to direct marketing, 635jl will cease processing your data for that purpose immediately.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible.
• Right to Damages: The right to seek compensation for damages suffered as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data, in accordance with the DPA.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 635jl has not complied with its obligations under the Data Privacy Act.

To exercise any of the rights listed above, please contact 635jl's Data Protection Officer at the contact details provided in Section 13. 635jl will respond to verified data subject requests within fifteen (15) business days of receipt. Complex requests may require additional time, in which case you will be notified of the expected timeline.

11 Minors

The 635jl platform is strictly intended for adults aged 21 and above, consistent with PAGCOR regulations governing online gaming in the Philippines. 635jl does not knowingly collect personal data from any individual under the age of 21.

Age verification is conducted during the registration process, and 635jl reserves the right to request additional documentary proof of age at any time. Any account discovered to belong to a person under 21 years of age will be immediately suspended, any associated funds will be handled in accordance with applicable regulations, and the personal data of the underage individual will be deleted as promptly as is consistent with any reporting obligations to PAGCOR or other relevant authorities.

12 Changes to This Privacy Policy

635jl reserves the right to update this Privacy Policy from time to time to reflect changes in law, regulatory requirements, platform features, or our data processing practices. The most current version of this Policy will always be accessible at 635jl.org/privacy-policy.

When material changes are made to this Policy — such as changes to the categories of data we collect, the purposes for which we use it, or the third parties with whom we share it — we will notify registered users via email to their registered email address or via an in-platform notification, no later than fourteen (14) days before the change takes effect.

Your continued use of the 635jl platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree to the revised Policy, you must discontinue use of the platform and may request account closure through our customer support team.

13 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the manner in which 635jl processes your personal data, you may contact us through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly through the 635jl platform. This is the fastest way to reach our team for general privacy enquiries.
• Email — General Support: [email protected] — for general account and privacy queries. We aim to acknowledge all emails within one (1) business day.
• Email — Data Protection Officer: [email protected] — Please mark the subject line as "Data Privacy Request" to ensure your message is directed to the DPO. Formal data subject requests sent to this address will be acknowledged within five (5) business days.

635jl's Data Protection Officer is responsible for overseeing all data privacy compliance matters and can assist with data subject access requests, erasure requests, objection requests, and escalated privacy complaints.

If you are not satisfied with 635jl's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). Information about how to file a complaint with the NPC is available through the NPC's official channels.