Section 1
Overview
This Privacy Policy ("Policy") describes how 3jlr ("3jlr," "we," "us," or "our") collects, processes, stores, and protects the personal information of users ("you," "Player," or "User") who access or use the 3jlr website and associated services (the "Platform").
3jlr is committed to protecting the privacy and personal data of all players, in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission ("NPC").
By using the 3jlr Platform, you consent to the collection and processing of your personal data as described in this Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform and contact our support team to request account closure.
This Policy should be read alongside our Terms & Conditions and Responsible Gaming policy, which together form the complete agreement governing your use of 3jlr.
Section 2
Information We Collect
3jlr collects personal information that is necessary to provide our services, comply with legal obligations, and maintain the security and integrity of the Platform. The categories of personal data we collect include:
2.1 Registration & Identity Data
- Full legal name
- Date of birth (to verify you are 21 years of age or older)
- Nationality and country of residence
- Government-issued identification number (e.g., Philippine National ID, passport, driver's licence)
- Email address and mobile number
- Username and encrypted password
2.2 Financial Data
- GCash account number or PayMaya account details
- Bank account details (BPI, BDO, Metrobank, or other Philippine banks)
- Credit or debit card details (Visa, Mastercard) — stored in tokenised form only
- Transaction history, including deposits, withdrawals, and bonus credits
2.3 Technical & Usage Data
- IP address and approximate geolocation
- Device type, operating system, and browser information
- Session duration, pages visited, and features used
- Game history, betting patterns, and wagering activity
- Login timestamps and access logs
2.4 Communications Data
- Records of your communications with 3jlr support, including live chat transcripts and email correspondence
- Survey responses and feedback you voluntarily provide
- Marketing preferences and opt-in/opt-out records
2.5 Verification Documents
As part of our Know Your Customer (KYC) process required under PAGCOR regulations and Philippine anti-money laundering laws, we may collect copies of government-issued identification documents, proof of address, and proof of payment method ownership.
Section 3
How We Use Your Data
3jlr uses your personal data for the following purposes:
- Account management: To create, maintain, and administer your 3jlr account, including processing deposits and withdrawals.
- Identity verification: To verify your age (21+), identity, and eligibility to use the Platform in compliance with PAGCOR regulations and Philippine law.
- Service delivery: To provide access to games, promotions, and all features of the 3jlr Platform.
- Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
- Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, money laundering, and other illegal activities.
- Legal compliance: To comply with applicable Philippine laws, PAGCOR requirements, and court orders.
- Responsible gaming: To monitor gameplay patterns and identify players who may be at risk of problem gambling, and to enforce self-exclusion requests.
- Marketing communications: To send you promotional offers, bonuses, and updates about 3jlr — only where you have given your consent or where we have a legitimate interest to do so.
- Platform improvement: To analyse usage data and improve the functionality, performance, and user experience of the 3jlr Platform.
Section 4
Legal Basis for Processing
Under the Data Privacy Act of 2012, 3jlr processes your personal data on the following legal bases:
- Contractual necessity: Processing is necessary to perform our obligations under the Terms & Conditions you have agreed to, including account management and payment processing.
- Legal obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and tax obligations.
- Legitimate interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights.
- Consent: Where we rely on your consent — for example, for marketing communications — you may withdraw that consent at any time by contacting our support team or updating your account preferences.
Section 5
Sharing Your Data
3jlr does not sell your personal data to third parties. We may share your data with the following categories of recipients only where necessary and in accordance with applicable law:
- Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, to process your financial transactions.
- Identity verification providers: Third-party KYC and AML compliance service providers who assist us in verifying player identities.
- Game software providers: Licensed game developers and platform providers whose games are available on 3jlr, to the extent necessary to deliver gameplay.
- Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies, where required by law or regulation.
- Law enforcement: Philippine law enforcement agencies, where we are legally required or permitted to disclose information in connection with the investigation of criminal activity.
- Professional advisers: Lawyers, auditors, and accountants who are bound by professional confidentiality obligations.
All third parties with whom 3jlr shares personal data are required to handle that data in accordance with applicable privacy laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.
Section 6
Cookies & Tracking Technologies
3jlr uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session, and analyse usage patterns. The types of cookies we use include:
- Essential cookies: Required for the Platform to function correctly, including session management and security features. These cannot be disabled.
- Functional cookies: Remember your preferences, such as language settings and display options.
- Analytics cookies: Help us understand how players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymised where possible.
- Marketing cookies: Used to deliver relevant promotional content. These are only set where you have provided consent.
You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 3jlr Platform.
Section 7
Data Retention
3jlr retains your personal data for as long as your account is active and for a period thereafter as required by applicable law. Specifically:
- Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering regulations.
- Financial transaction records are retained for a minimum of five (5) years as required by the AMLC and Bureau of Internal Revenue (BIR) regulations.
- KYC documents are retained for the period required by PAGCOR and applicable AML laws.
- Marketing preference records are retained until you withdraw your consent or request deletion.
- Support communications are retained for up to three (3) years following resolution of the relevant matter.
Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised in accordance with our data disposal procedures.
Section 8
Data Security
3jlr implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:
- SSL/TLS encryption for all data transmitted between your device and the 3jlr Platform.
- Encryption of sensitive data at rest, including financial information and identity documents.
- Access controls limiting employee access to personal data on a need-to-know basis.
- Regular security audits and vulnerability assessments.
- Two-factor authentication options for player accounts.
- Secure, tokenised storage of payment card details — 3jlr does not store full card numbers.
While we take all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, 3jlr will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.
Section 9
Your Rights
Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 3jlr:
- Right to be informed: You have the right to know what personal data 3jlr collects about you and how it is used.
- Right of access: You may request a copy of the personal data we hold about you.
- Right to rectification: You may request correction of in
accurate or incomplete personal data we hold about you.
- Right to erasure: You may 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.
- Right to object: You may object to the processing of your personal data for direct marketing purposes at any time.
- Right to data portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
- Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
- Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.
To exercise any of these rights, please contact our Data Protection Officer at the email address listed in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days in accordance with the DPA.
Section 10
Minors
The 3jlr Platform is strictly intended for individuals who are 21 years of age or older. 3jlr 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 minor, we will take immediate steps to delete that data and close the associated account.
If you are a parent or guardian and believe that a minor has registered on the 3jlr Platform, please contact our support team immediately so that we can investigate and take appropriate action.
Section 11
International Data Transfers
In some cases, your personal data may be transferred to and processed in countries outside the Philippines — for example, where our technology partners or game software providers are based abroad. Where such transfers occur, 3jlr ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under Philippine law.
By using the 3jlr Platform, you consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.
Section 12
Policy Changes
3jlr 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 update the "Last Updated" date at the top of this page and, where required, notify you via your registered email address or through a prominent notice on the Platform.
Your continued use of the 3jlr Platform following the publication of any updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we protect your data.