Your Privacy Matters to 47jl

1 Overview and Scope

This Privacy Policy ("Policy") is issued by 47jl ("47jl," "we," "us," or "our") and applies to all personal information collected, processed, stored, and used in connection with your access to and use of the 47jl online gaming platform, including the website at 47jl.one, any associated mobile applications, and all related services (collectively, the "Platform").

This Policy is intended to inform you — as a registered player, prospective player, or visitor to the Platform — about the types of personal data we collect, the purposes for which we use it, the parties with whom we may share it, and the rights you have in relation to your personal data under Philippine law.

By accessing the Platform or registering a 47jl account, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

This Policy should be read together with the 47jl Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2 Personal Data We Collect

47jl collects personal data from you in the following ways: directly from you when you register an account or interact with the Platform; automatically through your use of the Platform; and from third-party service providers involved in payment processing and identity verification.

2.1 Registration and Account Data. When you create a 47jl account, we collect:

• Full legal name
• Date of birth (for age verification — you must be 21 or older)
• Philippine mobile number
• Email address
• Username and encrypted password
• Residential address (for KYC verification)

2.2 Identity Verification (KYC) Data. To comply with anti-money laundering regulations and PAGCOR requirements, we may collect:

• Copies of government-issued identification (PhilSys ID, passport, driver's license, UMID, or other PAGCOR-accepted IDs)
• Selfie or live photo for facial verification
• Proof of address (utility bill, bank statement dated within 3 months)
• Source of funds documentation where required

2.3 Financial and Transaction Data. When you make deposits or withdrawals, we collect:

• GCash or Maya account number (last digits only, for verification)
• Bank account details for bank transfer transactions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank)
• Debit card details (processed securely by our payment provider; 47jl does not store full card numbers)
• Transaction history, amounts, dates, and payment method references

2.4 Gaming Activity Data. We automatically record your gaming activity on the Platform, including game sessions, wagers placed, outcomes, bonus usage, and session duration. This data is used for account management, dispute resolution, and responsible gaming monitoring.

2.5 Technical and Device Data. When you access the Platform, we automatically collect certain technical information, including your IP address, browser type and version, operating system, device identifiers, referring URLs, and pages visited. This data is collected via cookies and similar technologies as described in Section 8.

2.6 Communications Data. If you contact our customer support team, we retain records of those communications, including chat transcripts, emails, and call logs, for quality assurance and dispute resolution purposes.

3 How We Use Your Personal Data

47jl uses your personal data for the following purposes:

Purpose	Data Used
Account registration and management	Name, email, mobile number, date of birth, username
Identity verification (KYC/AML compliance)	Government ID, selfie, proof of address, source of funds
Processing deposits and withdrawals	Payment method details, transaction history
Providing and improving gaming services	Gaming activity data, device and technical data
Responsible gaming monitoring	Gaming activity, session data, deposit and loss history
Customer support and dispute resolution	Communications data, account data, transaction history
Fraud prevention and security	IP address, device data, transaction patterns
Regulatory compliance and reporting	All categories as required by applicable law
Platform analytics and performance	Technical data, usage patterns (aggregated/anonymized)
Promotional communications (with consent)	Email address, mobile number, gaming preferences

47jl will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

4 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173), 47jl processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to when registering your account, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering obligations, PAGCOR compliance requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for 47jl's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of promotional communications. You may withdraw your consent at any time by contacting our support team or updating your account preferences.

5 Data Sharing and Disclosure

47jl does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment service providers: GCash, Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the processing of deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• Identity verification providers: Third-party KYC and AML compliance service providers engaged to verify your identity and comply with regulatory requirements. These providers process your data under strict confidentiality obligations.
• Game software providers: Licensed game studios and software providers whose games are available on the 47jl Platform. These providers may receive anonymized session data for game performance purposes.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or regulatory order.
• Professional advisors: Legal counsel, auditors, and other professional advisors engaged by 47jl, subject to professional confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of 47jl's assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom 47jl shares personal data are required to implement appropriate technical and organizational security measures and to process your data only for the specified purposes.

6 Data Retention

47jl retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AML record-keeping requirements.
• KYC and identity verification data: Retained for a minimum of five (5) years following the end of the business relationship, as required by the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Gaming activity data: Retained for a minimum of three (3) years for dispute resolution and responsible gaming purposes.
• Communications data: Retained for two (2) years from the date of the communication.
• Technical and device data: Retained for up to twelve (12) months for security and analytics purposes.

When personal data is no longer required for any of the above purposes, 47jl will securely delete or anonymize it in accordance with our data disposal procedures.

7 Data Security

47jl implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the 47jl Platform
• AES-256 encryption for sensitive data stored in our databases
• Multi-factor authentication options for player accounts
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security audits and penetration testing of the Platform
• Secure data centers with physical access controls
• Staff training on data protection and information security

While 47jl takes all reasonable steps to protect your personal 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 notifying 47jl immediately if you suspect any unauthorized access to your account.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 47jl will notify the National Privacy Commission and affected players within seventy-two (72) hours of becoming aware of the breach, as required by the Data Privacy Act of 2012.

8 Cookies and Tracking Technologies

47jl uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit a website. We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled without affecting Platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display preferences, to provide a more personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized information about how players use the Platform, including pages visited, time spent, and navigation paths. This data helps us improve Platform performance and user experience.

47jl does not use advertising cookies, cross-site tracking cookies, or third-party behavioral profiling technologies. You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may affect your ability to use certain features of the Platform.

9 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by 47jl:

• Right to be informed: The right to be informed about how your personal data is collected, used, and processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data 47jl holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to 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: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: 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 the 47jl Data Protection Officer via our customer support channels. We will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

10 Minors and Age Restriction

The 47jl Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gambling regulations. 47jl does not knowingly collect personal data from individuals under the age of 21.

If 47jl becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data, and return any deposited funds to the original payment method. If you believe a minor has registered on the Platform, please contact our support team immediately.

11 Changes to This Privacy Policy

47jl reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When we make material changes to this Policy, we will notify registered players via email or in-platform notification at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the Platform following the effective date of any changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

12 Contact and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 47jl, please contact our Data Protection Officer through our customer support team. Our support email is displayed in the footer of this page.

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 (NPC) at privacy.gov.ph.