At 35jl, we take the privacy of every Filipino player seriously. This Privacy Policy explains exactly what personal data we collect, why we collect it, how we use and protect it, who we may share it with under Philippine law, and what rights you have as a data subject under the Data Privacy Act of 2012. This policy applies to all users of the 35jl website and mobile application.
35jl ("we," "us," or "our") operates the online gaming and betting platform accessible at 35jl.club and through the 35jl mobile application for Android. 35jl operates under the oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and in compliance with all applicable Philippine laws, including Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), and its implementing rules and regulations.
For the purposes of the Data Privacy Act of 2012, 35jl is the Personal Information Controller — the entity that determines the purposes and means by which personal data collected from users of the 35jl platform is processed. Where 35jl engages third-party service providers to process data on its behalf, those providers act as Personal Information Processors and are contractually bound to process data solely on 35jl's instructions and in compliance with applicable privacy law.
35jl collects the following categories of personal data from users of the platform. Data collection is limited to what is necessary, proportionate, and relevant to the purposes identified in this policy.
| Category | Data Elements | Required / Optional |
|---|---|---|
| Registration Data | Mobile number, username, password (hashed), date of birth, agreement to Terms | Required |
| Identity Verification (KYC) | Full legal name, government-issued ID number and image (UMID, PhilSys, driver's license, passport), date of birth, nationality | Required for withdrawals above threshold |
| Financial Data | GCash account number, PayMaya account number, BPI/BDO/Metrobank account details, transaction history, deposit and withdrawal amounts | Required for transactions |
| Device & Technical Data | IP address, device type and model, operating system version, browser type and version, mobile network operator, screen resolution | Collected automatically |
| Usage & Gaming Data | Session timestamps, games played, bets placed, game outcomes, bonus redemptions, tournament participation | Collected automatically |
| Communications Data | Live chat transcripts, support email correspondence, SMS records | When you contact support |
| Responsible Gaming Data | Self-exclusion status, deposit limit settings, session limit preferences, cooling-off period records | When you use these tools |
| Location Data | Approximate geographic location derived from IP address | Collected automatically |
35jl collects personal data through the following channels:
35jl processes personal data only for specific, legitimate, and declared purposes. The purposes for which we process your data are set out below:
Under the Data Privacy Act of 2012, 35jl processes personal data on the following legal bases:
6.1 We do not sell your personal data. 35jl does not sell, rent, trade, or otherwise commercially disclose your personal data to third parties for their own marketing or commercial purposes. Full stop.
6.2 Service Providers (Personal Information Processors). We engage trusted third-party service providers to process data on our behalf for specific, limited purposes. These include:
All service providers are bound by data processing agreements requiring compliance with the Data Privacy Act of 2012 and limiting their use of your data strictly to the purposes for which they are engaged.
6.3 Regulatory and Law Enforcement Disclosure. 35jl will disclose personal data to PAGCOR, the AMLC, the National Privacy Commission, the National Bureau of Investigation, and other Philippine government authorities where: (a) required to do so by valid legal process (court order, regulatory directive, or statutory mandate); (b) necessary to comply with the Anti-Money Laundering Act; or (c) necessary to protect the rights, property, or safety of 35jl, its users, or the general public.
6.4 Business Transfers. In the event of a merger, acquisition, or sale of substantially all of 35jl's assets, your personal data may be transferred as part of that transaction, subject to the acquirer assuming all obligations under this Privacy Policy and applicable Philippine privacy law. You will be notified of any such transfer in advance.
35jl retains personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to minimum retention periods required by applicable Philippine law:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of account + 5 years after closure | PAGCOR, RA 9160 (AMLA) |
| KYC / identity documents | 5 years after account closure | RA 9160 (AMLA) |
| Financial transaction records | 5 years from transaction date | RA 9160 (AMLA), PAGCOR |
| Gaming session logs | 3 years from session date | PAGCOR audit requirements |
| Customer support records | 3 years from last interaction | Legitimate interest, dispute resolution |
| Self-exclusion records | Permanently (to prevent re-registration) | PAGCOR responsible gaming |
| Marketing preferences | Until consent is withdrawn + 1 year | Consent |
Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in a manner that prevents reconstruction of the original data. Anonymized and aggregated data that cannot reasonably identify any individual may be retained indefinitely for platform improvement and statistical purposes.
35jl implements organizational, technical, and physical security measures designed to protect personal data against unauthorized access, disclosure, alteration, destruction, or loss. These measures include:
35jl uses cookies and similar tracking technologies on the 35jl website and within the mobile application. Cookies are small data files stored on your device that allow the platform to recognize you across sessions and improve your experience.
| Cookie Type | Purpose | Can You Opt Out? |
|---|---|---|
| Strictly Necessary | Session management, authentication, fraud prevention, load balancing. Required for the platform to function. | No — essential cookies cannot be disabled without breaking platform functionality. |
| Functional | Remembering your language preference, last-visited game, and login convenience settings. | Yes — disabling these will reset your preferences on each visit. |
| Analytics | Aggregated, anonymized data on how users navigate the platform — used to identify usability issues and improve the product. | Yes — opt out via cookie settings or browser settings. |
| Security | Detecting automated bot activity, brute-force login attempts, and suspicious session behavior. | No — security cookies are required to protect your account. |
You can manage cookie preferences through your browser settings. Most modern browsers — including Chrome, Firefox, Samsung Internet, and Safari Mobile — allow you to block or delete cookies. Note that blocking strictly necessary cookies will prevent you from logging in to the 35jl platform.
The 35jl platform is strictly prohibited for persons under 21 years of age in accordance with Philippine law and PAGCOR regulations. 35jl does not knowingly collect personal data from any person under the age of 21.
If 35jl discovers or has reasonable grounds to believe that a user is under 21 years of age, that user's account will be immediately suspended, any funds in the account will be frozen pending investigation, and the matter may be reported to PAGCOR. Any personal data collected from an underage user prior to discovery will be deleted as soon as reasonably practicable following account suspension.
Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 35jl. To exercise any of these rights, contact our Data Protection Officer using the details in Section 15.
Obtain confirmation of whether 35jl holds your personal data and receive a copy of it upon verified request.
Request correction of inaccurate, incomplete, or outdated personal data held by 35jl.
Request deletion of your personal data where no longer needed for the purposes it was collected, subject to legal retention requirements.
Object to processing of your personal data based on legitimate interests, including direct marketing and profiling.
Receive your personal data in a structured, machine-readable format for transfer to another controller.
Withdraw any consent you have given at any time without affecting the lawfulness of prior processing.
Lodge a complaint with the National Privacy Commission if you believe your data rights have been violated.
Be informed of how your personal data is collected, used, disclosed, and stored — which is the purpose of this Privacy Policy.
The 35jl platform is primarily hosted on infrastructure located within the Philippines and the Asia-Pacific region. In limited circumstances, certain service providers engaged by 35jl — including cloud hosting vendors and game technology partners — may process data on servers located outside the Philippines.
Where personal data is transferred outside the Philippines, 35jl ensures that such transfers are lawful under the Data Privacy Act of 2012 by implementing appropriate safeguards, which may include: standard contractual clauses approved by the National Privacy Commission; transfers to jurisdictions with adequate levels of data protection as determined by the NPC; or other legally recognized transfer mechanisms.
In no case will personal data be transferred to a jurisdiction that does not provide adequate protection for the rights of Filipino data subjects, as required under Section 21 of the Data Privacy Act of 2012.
If you have a concern about the way 35jl handles your personal data, we encourage you to raise it with us first so that we can attempt to resolve it directly. Contact our Data Protection Officer (DPO) using the details in Section 15, and we will acknowledge your complaint within 5 business days and provide a substantive response within 30 calendar days.
If you are not satisfied with 35jl's response, or if you believe 35jl has violated your rights under the Data Privacy Act of 2012, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory authority responsible for enforcing the Data Privacy Act and can be contacted at:
35jl reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, new legal requirements, regulatory guidance from the NPC, or changes to the 35jl platform. When material changes are made, we will provide advance notice through the platform — including a notice on the login screen and/or an SMS to your registered mobile number — before the changes take effect.
The effective date at the top of this policy indicates the date on which the current version came into force. We encourage you to review this policy periodically. Your continued use of the 35jl platform after a policy update is posted constitutes your acknowledgment of the updated policy.
For any privacy-related question, data subject access request, complaint, or correspondence regarding this Privacy Policy, please contact the 35jl Data Protection Officer through the following channels:
Privacy at 35jl is not a compliance checkbox — it's a core operational commitment that affects how we build and run every part of the platform.
35jl's data handling practices are fully aligned with Republic Act No. 10173 — the Data Privacy Act of 2012 — and its Implementing Rules. We are registered with the National Privacy Commission and maintain a designated Data Protection Officer as required by law. Filipino data subjects' rights are not optional features — they are legal obligations we honor.
Your data is encrypted in transit via TLS 1.3 and at rest via AES-256 — the same encryption standards used by BDO Online Banking and major Philippine fintech platforms. Passwords are never stored in recoverable form. Your GCash account number and ID documents are encrypted separately from your gaming data, with restricted internal access.
35jl does not and will not sell, rent, or trade your personal data to data brokers, advertising networks, or any unrelated third party for commercial gain. Your gaming history, contact details, and identity documents belong to you — they are used only to operate your account and meet our legal obligations, nothing else.
The Data Privacy Act of 2012 gives you eight enumerated rights over your personal data — including the right to access, correct, erase, object to, and export it. 35jl's DPO team processes verified data rights requests within 30 days. Exercising your rights costs nothing and requires no justification for most standard requests.
35jl collects only the personal data strictly required for each specific purpose. We do not collect your full address for account registration, we do not require a selfie for basic KYC, and we do not track your precise GPS location. Data minimization is a regulatory requirement under RA 10173 and a genuine design principle for 35jl.
In the event of a personal data breach that poses a real risk of harm to any 35jl player, we are legally required — and committed — to notify both the National Privacy Commission and affected data subjects within 72 hours of becoming aware of the breach. You will never be left in the dark about a security incident involving your data.
PAGCOR-regulated, NPC-registered, and built on genuine respect for your privacy. Join over 2 million Filipino players — deposit from ₱20 via GCash, play responsibly, and keep full control of your data. 21+ only.