78jl Privacy Policy

1.1 This Privacy Policy applies to all personal data collected, processed, and stored by 78jl in connection with the operation of its online gaming platform accessible at 78jl.org (the "Platform"). It covers all individuals who interact with the Platform, including registered Players, applicants for registration, and visitors who browse without registering.

1.2 78jl is committed to protecting the privacy and personal data of all Filipino players who use our services. This commitment is grounded in the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), which together establish the legal framework for personal data protection in the Philippines.

1.3 This Policy should be read together with the 78jl Terms and Conditions, which govern the overall relationship between 78jl and its Players. In the event of any conflict between this Policy and the Terms and Conditions on a privacy matter, this Policy shall prevail.

1.4 This Policy does not apply to third-party websites, platforms, or services that may be referenced on the 78jl Platform. 78jl is not responsible for the privacy practices of any third party, and Players should review the privacy policies of any external service they choose to interact with.

2.1 For the purposes of the Philippine Data Privacy Act of 2012, 78jl is the Personal Information Controller in respect of all personal data processed under this Policy. As the controller, 78jl determines the purposes and means by which your personal data is processed.

2.2 78jl has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Policy. The DPO serves as the primary point of contact for all privacy-related queries, complaints, and rights exercise requests from Players.

2.3 Contact details for the 78jl Data Protection Officer are provided in Section 14 of this Policy. Players are encouraged to contact the DPO directly for any data privacy concern that cannot be resolved through standard customer support channels.

3.1 78jl collects personal data through the following channels: the account registration process, ongoing use of the Platform, KYC document submission, payment transactions, customer support interactions, and automated technical data collection from your device and browser. The categories of personal data collected include:

3.1.1 Account Registration Data

• Philippine mobile number (primary account identifier);
• Date of birth (for age verification purposes);
• Chosen account password (stored in irreversibly hashed form — never in plaintext);
• Preferred currency (Philippine Peso / PHP by default).

3.1.2 Identity Verification (KYC) Data

• Full legal name as appearing on government-issued identification;
• Date of birth (cross-referenced against ID document);
• Government ID type and ID number (PhilSys, UMID, driver's license, passport, or Voter's ID);
• Photographic image of the submitted ID document;
• Selfie photograph, where requested during enhanced KYC procedures;
• Residential address, where requested for compliance purposes.

3.1.3 Financial Transaction Data

• Deposit amounts, dates, and payment methods (GCash, PayMaya, BPI, BDO, Metrobank, USDT);
• Withdrawal amounts, dates, and destination payment methods;
• Payment method account numbers or identifiers (e.g., GCash-registered mobile number), where required for transaction processing;
• Transaction reference numbers and processing status records.

3.1.4 Gaming Activity Data

• Game sessions played, game titles, bet amounts, and game outcomes;
• Bonus and promotional credits — awarded, wagered, and forfeited amounts;
• Responsible gaming tool settings — deposit limits, session limits, self-exclusion status.

3.1.5 Technical and Device Data

• IP address and approximate geographic location derived therefrom;
• Device type, operating system, and browser version;
• Session login timestamps and duration;
• Cookies and similar tracking technology data (see Section 8).

3.1.6 Communications Data

• Records of live chat support conversations;
• Email correspondence sent to 78jl by the Player;
• Formal complaint records and dispute submissions.

4.1 78jl uses the personal data described in Section 3 for the following specific purposes:

1. Account creation and management — to register your account, maintain your Account profile, and provide access to the Platform's features;
2. Identity and age verification — to confirm that you meet the 21+ age requirement and to verify your identity in compliance with PAGCOR KYC requirements;
3. Transaction processing — to process deposits and withdrawals to and from your Account wallet via your nominated Philippine payment method;
4. Platform security and fraud prevention — to detect, investigate, and prevent unauthorized Account access, duplicate account creation, bonus abuse, and financial fraud;
5. Anti-money laundering compliance — to monitor transaction patterns and fulfill 78jl's reporting obligations under Philippine AML laws, including the Anti-Money Laundering Act (AMLA) as amended;
6. Responsible gaming — to monitor gaming behavior, apply player-configured limits and exclusions, and intervene where there are signs of problem gambling that 78jl is obligated to address under PAGCOR regulations;
7. Customer support — to handle your support queries, complaints, and dispute submissions;
8. Service communications — to send transaction confirmations, account notifications, security alerts, and other service-essential messages via SMS or email;
9. Regulatory compliance and record-keeping — to maintain records required by PAGCOR's licensing conditions and other applicable Philippine law;
10. Platform improvement — to analyze anonymized and aggregated usage data to improve game offerings, interface design, and service quality. No individually identifiable data is used for platform improvement analytics.

5.1 Under the Philippine Data Privacy Act of 2012, 78jl processes your personal data on the following legal bases:

• Contractual necessity: Processing of account registration data, KYC data, payment data, and gaming activity data is necessary for the performance of the contract between 78jl and the Player (the Terms and Conditions). Without this processing, 78jl cannot provide the Platform services.
• Legal obligation: Processing for AML compliance, PAGCOR regulatory record-keeping, age verification, and financial crime reporting is required by applicable Philippine law and cannot be withdrawn by player consent.
• Legitimate interests: Processing for fraud prevention, platform security, and aggregated analytics is conducted on the basis of 78jl's legitimate interests in maintaining a secure and compliant platform, balanced against Players' privacy interests.
• Consent: Processing for marketing communications is conducted solely on the basis of the Player's freely given, specific, and informed consent. This consent can be withdrawn at any time with no adverse consequence to account access.

6.1 78jl does not sell, rent, or otherwise commercially transfer your personal data to any third party for that party's own use. Personal data is shared with third parties only in the following circumstances:

6.1.1 Service Providers (Processors)

78jl engages contracted third-party service providers who process personal data on 78jl's behalf and under 78jl's written instructions. These include: payment processing infrastructure providers; KYC and identity verification service providers; game content delivery platforms; cloud hosting and security infrastructure providers; and customer support technology providers. All such providers are contractually bound to process data only as instructed by 78jl and to maintain security standards consistent with the Data Privacy Act.

6.1.2 Regulatory and Law Enforcement Authorities

78jl is required by Philippine law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities upon lawful request or as required by 78jl's licensing conditions. Such disclosures are made without notice to the Player where required by applicable law or court order.

6.1.3 Corporate Transactions

In the event of a merger, acquisition, or asset sale involving 78jl, personal data held by 78jl may be transferred to the acquiring entity. In such an event, 78jl will notify registered Players via their registered mobile number or email address before any such transfer takes effect and will ensure the acquiring entity is bound by privacy obligations at least equivalent to those in this Policy.

7.1 As a PAGCOR-licensed operator, 78jl is legally required to implement Know Your Customer (KYC) procedures and to comply with anti-money laundering (AML) obligations under the Philippine Anti-Money Laundering Act (Republic Act No. 9160, as amended by RA 10365 and RA 11521).

7.2 KYC data — including government ID documents, selfie photographs, and personal identifying information — is processed by 78jl's verification team and, where applicable, by contracted third-party identity verification service providers. This data is used exclusively for identity verification, age confirmation, and compliance with PAGCOR and AMLC obligations.

7.3 Players are required to complete KYC verification before 78jl will process any withdrawal from their Account. This is a non-negotiable regulatory requirement and cannot be waived regardless of account balance or tenure.

7.4 78jl maintains transaction monitoring systems that analyze player deposit and withdrawal patterns to detect activity that may indicate money laundering, terrorist financing, or other financial crime. Where suspicious activity is detected, 78jl is required to submit Suspicious Transaction Reports (STRs) to the AMLC without notifying the Player that a report has been made (tipping-off prohibition under AMLA).

8.1 78jl uses cookies and similar tracking technologies on the Platform for the following purposes:

• Session cookies: Essential for maintaining your logged-in state during a Platform session. These expire automatically when your browser session ends.
• Security cookies: Used to detect fraudulent login attempts, CSRF attacks, and other security threats. These are required for Platform security and cannot be disabled.
• Preference cookies: Used to remember your Platform preferences (language, game lobby view settings) between sessions. These persist until cleared.
• Analytics cookies: Used to collect anonymized and aggregated data about how Players navigate the Platform, which pages are most visited, and where technical errors occur. This data is used solely to improve Platform performance and contains no personally identifiable information.

8.2 78jl does not use third-party advertising or retargeting cookies on the Platform. No tracking data from your 78jl session is shared with advertising networks or social media platforms.

8.3 Players may control non-essential cookies through their browser settings. Disabling session or security cookies will prevent access to the Platform and is not recommended. Detailed cookie settings and preferences are accessible through the cookie management panel available on the Platform.

9.1 78jl retains personal data for the minimum period necessary to fulfill the purposes for which it was collected, subject to the following specific retention standards:

9.2 Following the expiry of the applicable retention period, 78jl will securely delete or irreversibly anonymize your personal data in accordance with industry-standard data destruction practices. Anonymized, aggregated data that cannot be re-linked to any individual may be retained indefinitely for statistical purposes.

10.1 78jl implements a comprehensive set of technical and organizational security measures to protect player personal data against unauthorized access, accidental loss, destruction, or disclosure. Key measures include:

• Encryption: All personal data is encrypted at rest using AES-256 encryption. All data in transit between the Player's device and 78jl's servers is protected by TLS 1.2 or higher;
• Access controls: Access to personal data within 78jl's systems is restricted to employees and contractors with a documented operational need, enforced through role-based access controls and audit logging;
• Password security: Player passwords are never stored in recoverable form — only irreversible cryptographic hashes are retained in 78jl's authentication systems;
• Security monitoring: 78jl's systems are monitored continuously for unauthorized access attempts, anomalous login behavior, and other security incidents;
• Penetration testing: 78jl engages independent security assessors to conduct regular penetration testing of Platform infrastructure and application layers;
• Data breach response: 78jl maintains a documented data breach response procedure. In the event of a personal data breach likely to result in risk to affected Players, 78jl will notify the National Privacy Commission within 72 hours of awareness, as required under Section 20(f) of the Data Privacy Act.

11.1 Under the Philippine Data Privacy Act of 2012, all Filipino players have the following rights with respect to their personal data held by 78jl. These rights may be exercised at any time by contacting the 78jl Data Protection Officer as described in Section 14:

11.2 Rights requests will be acknowledged within five (5) business days and substantively responded to within thirty (30) days of receipt. Complex requests may require up to sixty (60) days with advance notice provided to the Player. Identity verification is required before any rights request is fulfilled to prevent unauthorized disclosure.

12.1 78jl does not knowingly collect personal data from any person under the age of 21. The KYC verification process specifically confirms that each registered Player meets the 21+ age requirement before full Account access is granted.

12.2 If 78jl becomes aware that personal data has been collected from a person under 21 years of age — whether through registration with a false date of birth or any other means — the relevant Account will be immediately suspended and all data associated with that Account will be securely deleted, except where retention is required by law.

12.3 Any person aware of a minor having registered on the 78jl Platform should report this to the 78jl Data Protection Officer at the contact details provided in Section 14. 78jl will act on such reports as a priority.

13.1 78jl may update this Privacy Policy from time to time to reflect changes in applicable law, PAGCOR regulatory requirements, our data processing practices, or the features and services available on the Platform.

13.2 For material changes that significantly affect Players' rights or the way their data is processed, 78jl will provide advance notice via SMS to registered mobile numbers at least fourteen (14) days before the changes take effect.

13.3 For non-material amendments — such as editorial corrections, clarifications that do not change substantive rights, or updates required immediately by regulatory direction — changes may take effect upon publication on the Platform.

13.4 The effective date and last-updated date displayed at the top of this Policy reflect when the current version became operative. Players who continue to use the Platform after a revised Policy has taken effect are deemed to have accepted the updated terms.

14.1 For any question, concern, rights request, or complaint relating to this Privacy Policy or the processing of your personal data by 78jl, please contact the 78jl Data Protection Officer through the following channels:

• Email (DPO): [email protected] — mark your message "Attention: Data Protection Officer" in the subject line for routing to the DPO team;
• Live Chat: Available 24/7 through your logged-in 78jl Account dashboard. For DPO matters, state at the start of the chat that your query is a Data Privacy Act request — the support agent will escalate accordingly.

14.2 Players who are not satisfied with 78jl's response to a data privacy concern may lodge a formal complaint with the National Privacy Commission of the Philippines. Information on the NPC complaints process is available through official NPC public channels.

14.3 78jl commits to treating all DPO communications with confidentiality and to responding to formal privacy inquiries within the timelines required by the Data Privacy Act and its IRR.