36ji Privacy Policy

1. Introduction

Welcome to the Privacy Policy of 36ji (https://36ji.cam), an online gaming platform operated in the Philippines. This Privacy Policy governs the collection, processing, storage, and protection of personal data obtained from users of our website and mobile applications (collectively, the "Platform"). By accessing or using the 36ji Platform, registering an account, or providing your personal information, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy.

36ji is committed to protecting the privacy and security of our users' personal information. We adhere to the principles outlined in Republic Act No. 10173, also known as the Data Privacy Act of 2012, along with its implementing rules and regulations issued by the National Privacy Commission (NPC) of the Philippines. We have implemented comprehensive technical, organizational, and physical safeguards to ensure that your personal data is processed lawfully, fairly, and in a transparent manner.

This Privacy Policy applies to all personal data collected through our Platform, whether you are a registered user, a visitor browsing our website, or a prospective customer making inquiries. It covers personal information collected directly from you, as well as information collected automatically through your use of our services. This policy should be read in conjunction with our Terms and Conditions and Responsible Gaming Policy, which provide additional context regarding your use of the Platform.

2. Information We Collect

2.1 Personal Information You Provide

When you register an account with 36ji, we collect personal information that you voluntarily provide to us. This information is necessary for account creation, identity verification, transaction processing, and compliance with regulatory requirements. The personal information we collect includes:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., PhilSys ID, SSS ID, Driver's License, Passport)
• Contact Information: Email address, mobile phone number, residential address, and postal code
• Account Credentials: Username, password, security questions and answers, and authentication codes
• Financial Information: Payment method details (GCash mobile number, Maya account, bank account numbers), transaction history, deposit and withdrawal records
• Verification Documents: Copies of government-issued identification, proof of address (utility bills, bank statements), selfie photos for identity verification, and proof of payment method ownership
• Communication Data: Messages sent through our customer support channels, chat transcripts, email correspondence, and survey responses

2.2 Information Collected Automatically

When you access and use the 36ji Platform, certain information is collected automatically through various technologies. This data helps us understand how users interact with our services, improve platform performance, detect fraudulent activities, and enhance user experience. Automatically collected information includes:

• Device Information: Device type, operating system, browser type and version, device identifiers (IMEI, MAC address), screen resolution, and device settings
• Usage Data: Pages visited, features used, time spent on pages, clickstream data, search queries, games played, bet history, and navigation patterns
• Location Data: IP address, approximate geographic location based on IP address, GPS coordinates (if permitted), and Wi-Fi access point information
• Technical Data: Log files, error reports, system activity, browser cookies, pixel tags, web beacons, and similar tracking technologies
• Gaming Data: Game preferences, wagering patterns, betting history, win/loss records, bonus usage, and promotional participation

2.3 Information from Third Parties

We may receive additional information about you from third-party sources to verify your identity, prevent fraud, or enhance our services. Third-party sources include:

• Payment service providers (GCash, Maya, banks) who confirm transaction details and account ownership
• Identity verification services that validate government-issued identification documents
• Credit bureaus and fraud prevention agencies for risk assessment purposes
• Marketing partners and affiliates who refer users to our Platform (with your consent)
• Public databases and government registries for regulatory compliance purposes

3. How We Use Your Information

3.1 Primary Purposes

36ji collects and processes your personal information for specific, legitimate purposes related to providing online gaming services. We use your data to:

• Account Management: Create and maintain your user account, authenticate your identity, verify your eligibility to use gaming services, and manage your account settings and preferences
• Transaction Processing: Process deposits and withdrawals, facilitate payments through your chosen payment methods, record financial transactions, and issue payment confirmations
• Service Delivery: Provide access to games and betting platforms, enable real-time gameplay, display personalized content, track gaming activity, and process wagers and payouts
• Customer Support: Respond to inquiries and support requests, resolve disputes and complaints, provide technical assistance, and communicate important account-related information
• Compliance and Legal Obligations: Verify your age and identity to prevent underage gambling, comply with anti-money laundering (AML) regulations, fulfill Know Your Customer (KYC) requirements, report suspicious activities to regulatory authorities, and maintain records as required by law

3.2 Secondary Purposes

With your consent, we may also use your personal information for additional purposes that enhance your experience on the 36ji Platform:

• Marketing and Promotions: Send promotional offers, bonuses, and special deals via email or SMS, notify you of new games and features, and provide personalized recommendations based on your gaming preferences
• Analytics and Improvement: Analyze user behavior to improve platform functionality, conduct market research and surveys, test new features and games, and optimize user experience
• Security and Fraud Prevention: Monitor for fraudulent activities and suspicious transactions, detect and prevent bonus abuse and account manipulation, investigate violations of our Terms and Conditions, and protect against cyber attacks and unauthorized access
• Responsible Gaming: Implement self-exclusion tools and deposit limits, identify patterns of problem gambling behavior, and provide resources for responsible gaming support

3.3 Legal Basis for Processing

We process your personal data based on the following legal grounds under Philippine law:

• Performance of a contract (providing gaming services as outlined in our Terms and Conditions)
• Compliance with legal obligations (age verification, AML/KYC requirements, regulatory reporting)
• Legitimate interests (fraud prevention, security, service improvement)
• Your explicit consent (marketing communications, optional data collection)

4. Information Sharing and Disclosure

4.1 Third-Party Service Providers

36ji engages trusted third-party service providers to support our operations and deliver high-quality gaming services. These providers have access to your personal information only to the extent necessary to perform their functions on our behalf and are contractually obligated to protect your data. We share information with:

• Payment Processors: GCash, Maya, Philippine banks, and cryptocurrency payment gateways that facilitate deposits and withdrawals
• Game Providers: Licensed software developers and game studios that supply casino games, slot machines, live dealer tables, and sports betting platforms
• Identity Verification Services: Third-party providers that authenticate government-issued IDs and verify user identities
• Cloud Hosting Providers: Servers and data centers that store and process platform data securely
• Customer Support Tools: Live chat platforms, ticketing systems, and communication software used to assist users
• Marketing Platforms: Email service providers and SMS gateways for promotional communications (only with your consent)
• Analytics Services: Tools that help us understand user behavior and improve our platform (e.g., Google Analytics)

4.2 Legal and Regulatory Disclosure

We may disclose your personal information to government authorities, regulatory bodies, and law enforcement agencies when required by law or when necessary to protect our legal rights. Disclosure may occur in the following circumstances:

• Compliance with court orders, subpoenas, or legal processes
• Response to requests from the National Privacy Commission, Philippine Amusement and Gaming Corporation (PAGCOR), or other regulatory authorities
• Reporting of suspicious transactions under Anti-Money Laundering Act (AMLA) requirements
• Cooperation with law enforcement investigations into fraud, money laundering, or other criminal activities
• Protection of 36ji's legal rights, property, or safety, or that of our users and the public

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor company. We will notify you via email or prominent notice on the Platform before your data is transferred and becomes subject to a different privacy policy.

4.4 No Sale of Personal Data

36ji does not sell, rent, or trade your personal information to third parties for their marketing purposes. Any sharing of data with third parties is strictly limited to the purposes outlined in this Privacy Policy and is governed by contractual agreements that require recipient parties to protect your information.

5. Data Security Measures

5.1 Technical Safeguards

36ji employs industry-standard technical security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Our security infrastructure includes:

• Encryption: All data transmitted between your device and our servers is protected using SSL/TLS encryption protocols. Sensitive data stored in our databases is encrypted using AES-256 encryption.
• Secure Servers: Our platform is hosted on secure servers located in certified data centers with 24/7 monitoring, redundant power supplies, and disaster recovery systems.
• Firewalls and Intrusion Detection: Advanced firewalls and intrusion detection systems monitor network traffic and block unauthorized access attempts.
• Access Controls: Strict access controls ensure that only authorized personnel can access personal data, and all access is logged and audited regularly.
• Regular Security Audits: We conduct periodic security assessments, penetration testing, and vulnerability scans to identify and address potential security risks.

5.2 Organizational Safeguards

In addition to technical measures, we have implemented organizational policies and procedures to ensure data protection:

• Employee training on data privacy and security best practices
• Confidentiality agreements with all staff members who handle personal data
• Data minimization principles to collect only necessary information
• Incident response plans for data breaches and security incidents
• Designated Data Protection Officer responsible for privacy compliance

5.3 User Responsibilities

While we take extensive measures to protect your data, account security also depends on your actions. You are responsible for:

• Keeping your password confidential and not sharing it with anyone
• Using strong, unique passwords that are not easily guessed
• Enabling two-factor authentication when available
• Logging out of your account after each session, especially on shared devices
• Notifying us immediately if you suspect unauthorized access to your account
• Using secure internet connections and avoiding public Wi-Fi for accessing your account

6. Data Retention and Storage

6.1 Retention Periods

36ji retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Accounts: Personal data associated with active accounts is retained for the duration of your account's existence and for a period after account closure as required by law.
• Transaction Records: Financial transaction data is retained for at least five (5) years after the transaction date, in compliance with Philippine tax and anti-money laundering regulations.
• Identity Verification Documents: Copies of government-issued IDs and verification documents are retained for seven (7) years after account closure or as required by regulatory authorities.
• Communication Logs: Customer support transcripts and email correspondence are retained for three (3) years for quality assurance and dispute resolution purposes.
• Marketing Data: Marketing preferences and communication history are retained until you withdraw consent or request deletion.

6.2 Data Deletion

Upon expiration of the retention period or when personal data is no longer necessary for its original purpose, we securely delete or anonymize the information. However, we may retain certain data if required by law, for legitimate business purposes (e.g., fraud prevention), or to resolve ongoing disputes.

6.3 Storage Locations

Your personal data is primarily stored on secure servers located within the Philippines. In some cases, data may be stored or processed in secure data centers outside the Philippines, provided that adequate safeguards are in place to ensure compliance with Philippine data protection laws.

7. Your Privacy Rights

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

7.1 Right to Access

You have the right to request access to the personal information we hold about you. Upon verification of your identity, we will provide you with a copy of your data in a structured, commonly used, and machine-readable format.

7.2 Right to Rectification

If you believe that any personal information we hold about you is inaccurate, incomplete, or outdated, you have the right to request correction or update of such data. You can update most account information directly through your account settings.

7.3 Right to Erasure

You may request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for its original purpose or when you withdraw consent. However, we may refuse deletion requests if we are legally required to retain the information or if retention is necessary for legitimate business purposes.

7.4 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes or when processing is based on legitimate interests. If you object to marketing communications, we will immediately cease sending such messages.

7.5 Right to Data Portability

You have the right to receive your personal data in a portable format and transmit it to another service provider, where technically feasible.

7.6 Right to Withdraw Consent

If we process your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing prior to the withdrawal.

7.7 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer at the contact information provided in Section 12 below. We will respond to your request within fifteen (15) business days and may require verification of your identity before processing your request.

8. Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files stored on your device when you visit the 36ji Platform. They help us recognize your device, remember your preferences, and improve your user experience. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device until deleted).

8.2 Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function properly, including authentication, security, and navigation features.
• Performance Cookies: Collect anonymous data about how users interact with the Platform to help us improve performance and user experience.
• Functionality Cookies: Remember your preferences, such as language settings, display options, and favorite games.
• Marketing Cookies: Track your browsing activity to deliver personalized advertisements and promotional content (only with your consent).

8.3 Managing Cookies

You can manage or delete cookies through your browser settings. However, disabling essential cookies may affect the functionality of the Platform. Most browsers allow you to block third-party cookies while still accepting first-party cookies from the sites you visit.

9. Protection of Minors

The 36ji Platform is strictly intended for individuals aged 21 years or older. We do not knowingly collect personal information from individuals under the legal gambling age. If we discover that we have inadvertently collected data from a minor, we will immediately delete such information and close the associated account.

Parents and guardians are encouraged to monitor their children's online activities and prevent underage access to gambling websites. If you believe that a minor has provided personal information to 36ji, please contact us immediately so we can take appropriate action.

10. International Data Transfers

While 36ji primarily operates within the Philippines, some of our service providers and partners may be located in other countries. When personal data is transferred outside the Philippines, we ensure that appropriate safeguards are in place, such as:

• Contractual agreements requiring recipient parties to comply with Philippine data protection standards
• Use of service providers that are certified under internationally recognized data protection frameworks
• Implementation of encryption and security measures during data transmission
• Compliance with cross-border data transfer requirements under the Data Privacy Act

11. Changes to Privacy Policy

36ji reserves the right to update, modify, or revise this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes to this policy will be communicated via email to registered users and through a prominent notice on the Platform.

The "Last Updated" date at the top of this policy indicates when the most recent changes were made. Your continued use of the Platform after changes are posted constitutes your acceptance of the revised Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

12. Contact Information

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

• Email: [email protected]
• Customer Support: [email protected]
• Live Chat: Available 24/7 through the Platform
• Support Center: /support

For complaints or concerns that we cannot resolve directly, you have the right to file a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission
• 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City, Metro Manila 1307
• Email: [email protected]
• Website: https://www.privacy.gov.ph