621jl Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 621jl ("621jl," "we," "us," or "our") collects, uses, discloses, stores, and protects the personal information of users ("User," "Player," "you," or "your") who access or use the 621jl online gaming platform, including the website located at https://621jl.cam, mobile applications, and related services (collectively, the "Platform"). This Policy applies to all personal data processed by 621jl in connection with your use of the Platform, whether collected directly from you or obtained from third-party sources.

621jl is committed to protecting your privacy and complying with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Republic of the Philippines, as well as all applicable Philippine Amusement and Gaming Corporation (PAGCOR) regulations governing online gaming operations. By accessing the Platform or creating an account with 621jl, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Policy.

If you do not agree with this Privacy Policy, you must immediately discontinue use of the Platform and refrain from providing any personal information to 621jl.

2. Information We Collect

621jl collects various categories of personal information to provide, maintain, and improve the Platform and to comply with legal and regulatory obligations. The types of information we collect include:

2.1 Information You Provide Directly

• Account Registration Information: When you create an account, we collect your full legal name, date of birth, email address, mobile phone number, residential address, username, and password.
• Identity Verification Documents: To comply with PAGCOR know-your-customer (KYC) and anti-money laundering (AML) requirements, we collect copies of government-issued identification documents (passport, driver's license, national ID), proof of address (utility bills, bank statements), and proof of payment method ownership (bank statements, screenshots of e-wallet accounts).
• Financial and Transaction Information: We collect payment method details (e-wallet account numbers, bank account numbers), transaction history (deposits, withdrawals, bets placed, winnings), and related financial records necessary to process payments and comply with financial regulations.
• Communication Records: When you contact customer support via email, live chat, or phone, we collect and store the content of your communications, including messages, attachments, and call recordings for quality assurance and dispute resolution purposes.
• Marketing Preferences: If you opt in to receive promotional communications, we collect your marketing preferences and consent records.

2.2 Information Collected Automatically

• Device and Technical Information: We automatically collect information about the device you use to access the Platform, including IP address, device type, operating system, browser type and version, screen resolution, and unique device identifiers.
• Usage and Activity Data: We collect information about your interactions with the Platform, including pages visited, games played, bet amounts, session duration, clickstream data, and referral sources.
• Geolocation Information: We collect your approximate geographic location based on your IP address to verify that you are accessing the Platform from a jurisdiction where online gaming is legal and to comply with geo-blocking requirements.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your browsing behavior, preferences, and interactions with the Platform. For more information, please refer to our Cookie Policy (if applicable) or the section on cookies below.

2.3 Information from Third-Party Sources

• Payment Processors: We receive transaction confirmation data from third-party payment processors such as GCash, PayMaya, and participating banks.
• Identity Verification Services: We may use third-party identity verification services to validate the authenticity of documents you provide and to screen for fraud, money laundering, or other illegal activity.
• Game Providers: We receive gameplay and bet history data from third-party game developers and providers whose games are available on the Platform.

3. How We Use Your Information

621jl uses your personal information for the following purposes:

3.1 Service Provision and Account Management

• To create, maintain, and manage your 621jl account
• To process deposits, withdrawals, and other financial transactions
• To provide access to games, betting markets, and other Platform features
• To authenticate your identity and verify your eligibility to use the Platform
• To provide customer support and respond to your inquiries
• To communicate important account-related information, including updates to terms, policies, and security notices

3.2 Legal and Regulatory Compliance

• To comply with PAGCOR licensing requirements, including KYC, AML, and responsible gaming regulations
• To verify that you are at least 21 years of age and meet all eligibility requirements
• To detect, prevent, and investigate fraud, money laundering, terrorist financing, and other illegal activities
• To respond to legal process, including court orders, subpoenas, and requests from law enforcement or regulatory authorities
• To maintain records required by Philippine law and PAGCOR regulations

3.3 Security and Fraud Prevention

• To monitor and analyze Platform activity for suspicious behavior, account abuse, and security threats
• To protect the security and integrity of the Platform and prevent unauthorized access
• To enforce our Terms and Conditions and other policies
• To investigate and resolve disputes between users or between users and 621jl

3.4 Marketing and Personalization

• To send you promotional offers, bonuses, newsletters, and other marketing communications if you have opted in to receive such communications
• To personalize your experience on the Platform by recommending games, promotions, and content based on your preferences and activity
• To conduct surveys, contests, and promotional campaigns

3.5 Analytics and Improvement

• To analyze Platform usage patterns and user behavior to improve our services, features, and user experience
• To develop new products, services, and features
• To conduct research and generate statistical reports on Platform performance and user demographics

4. Legal Basis for Processing

Under Philippine data protection law, we process your personal information based on one or more of the following legal grounds:

• Consent: You have provided explicit consent for the processing of your personal data for specific purposes, such as receiving marketing communications.
• Contractual Necessity: Processing is necessary to perform the contract between you and 621jl (the Terms and Conditions), including account creation, payment processing, and service delivery.
• Legal Obligation: Processing is required to comply with Philippine law, PAGCOR regulations, AML requirements, tax obligations, and other legal duties.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, and service improvement, provided such interests do not override your fundamental rights and freedoms.

5. How We Share Your Information

621jl does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients:

5.1 Service Providers and Business Partners

We share your information with third-party service providers who perform services on our behalf, including:

• Payment processors (GCash, PayMaya, banks) to process deposits and withdrawals
• Identity verification and fraud prevention services to verify your identity and screen for illegal activity
• Game developers and providers to deliver gaming content and record gameplay data
• Cloud hosting and data storage providers to store and secure your information
• Customer support and communication platforms to provide support services
• Marketing and analytics providers to deliver targeted advertising and analyze Platform performance (only if you have consented to marketing communications)

These service providers are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.

5.2 Regulatory and Law Enforcement Authorities

We may disclose your information to PAGCOR, the National Privacy Commission, law enforcement agencies, tax authorities, and other governmental bodies when required by law, court order, or legal process, or when necessary to comply with regulatory obligations, investigate fraud, or protect the rights, safety, and property of 621jl and its users.

5.3 Business Transfers

In the event of a merger, acquisition, sale of assets, bankruptcy, or other business transaction involving 621jl, your personal information may be transferred to the acquiring or surviving entity, subject to the same privacy protections as outlined in this Policy.

5.4 With Your Consent

We may share your information with third parties when you provide explicit consent for such disclosure, such as participating in third-party promotions or integrating with social media platforms.

6. Data Security

621jl implements industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL (Secure Socket Layer) encryption for all data transmitted between your device and our servers
• Encrypted storage of sensitive personal and financial data
• Access controls limiting employee access to personal data on a need-to-know basis
• Regular security audits and penetration testing to identify and remediate vulnerabilities
• Firewall protection and intrusion detection systems to prevent unauthorized access to our systems
• Multi-factor authentication for administrative and high-privilege accounts

While we take all reasonable measures to protect your data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

7. Data Retention

621jl retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Account Information: Retained for the duration of your active account and for five (5) years after account closure to comply with PAGCOR record-keeping requirements.
• Transaction Records: Retained for five (5) years in accordance with Philippine AML regulations and tax laws.
• Identity Verification Documents: Retained for five (5) years after account closure in accordance with PAGCOR KYC requirements.
• Marketing Communications: Retained until you withdraw your consent or for two (2) years after your last interaction with 621jl, whichever is earlier.
• Customer Support Records: Retained for three (3) years to facilitate dispute resolution and service improvement.

After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with our data retention and disposal policies.

8. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

8.1 Right to Access

You have the right to request access to the personal information we hold about you, including details about the types of data collected, the purposes of processing, and the recipients of your data.

8.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You may update certain account information directly through your account settings.

8.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal information, subject to legal and regulatory retention requirements. Please note that we may be required to retain certain information for compliance purposes even after account closure.

8.4 Right to Object

You have the right to object to the processing of your personal information for direct marketing purposes. You may opt out of marketing communications at any time by following the unsubscribe instructions in our emails or by contacting customer support.

8.5 Right to Data Portability

You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format for transfer to another service provider.

8.6 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 based on consent before withdrawal.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within thirty (30) days.

9. Cookies and Tracking Technologies

621jl uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize your browser and remember your preferences. You can control cookie settings through your browser, but disabling cookies may limit certain Platform features.

10. Third-Party Links

The Platform may contain links to third-party websites, services, or applications that are not operated or controlled by 621jl. This Privacy Policy does not apply to third-party sites. We are not responsible for the privacy practices or content of third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

11. Children's Privacy

The Platform is intended solely for individuals who are at least 21 years of age. 621jl does not knowingly collect, use, or disclose personal information from individuals under the age of 21. If we become aware that we have collected personal information from a person under 21 years of age, we will promptly delete that information and close the associated account.

12. International Data Transfers

Your personal information is primarily processed and stored within the Republic of the Philippines. If we transfer your information to service providers located outside the Philippines, we will ensure that appropriate safeguards are in place to protect your data in accordance with Philippine data protection law.

13. Changes to This Privacy Policy

621jl reserves the right to amend, modify, or update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. We will notify you of material changes by posting the updated Policy on the Platform and updating the "Last Updated" date at the top of this page. Your continued use of the Platform following the posting of changes constitutes your acceptance of the revised Privacy Policy.

14. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data processing practices, or if you wish to exercise your privacy rights, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 through your account dashboard
• Operating Address: Metro Manila, Philippines

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

By using the 621jl Platform, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.