Privacy Policy

1 Introduction

21jl ("we," "us," "our," or "the Company") is committed to protecting the privacy and personal data of all players who use the 21jl platform (https://21jl.app). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in connection with your use of the 21jl website, mobile application, and all related services (collectively, the "Platform").

This policy is intended to comply with applicable Philippine data privacy laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations. We take our obligations under Philippine law seriously, and we are committed to handling your personal data with transparency, fairness, and security.

Please read this Privacy Policy carefully. By accessing or using the 21jl Platform, you confirm that you haveread, understood, and agree to the practices described herein. If you do not agree with this Privacy Policy, you must not use the Platform.

2 Data Controller

For the purposes of applicable data privacy legislation, 21jl is the data controller responsible for your personal information collected through the Platform. As data controller, 21jl determines the purposes and means by which your personal data is processed.

If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact our Data Protection Officer (DPO) directly at [email protected]. We will respond to all data privacy inquiries within fifteen (15) business days.

3 Data We Collect

21jl collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include the following:

3.1 Identity & Contact Data

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Government-issued identification number (e.g., Philippine passport, SSS, UMID, or driver's license number)

3.2 Financial Data

• GCash or PayMaya account details (mobile number linked to the account)
• Bank account details for BPI, BDO, or Metrobank transfers (account name and number)
• Transaction history, including deposits, withdrawals, and wager records
• Source of funds documentation where required for compliance purposes

3.3 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps, login history, and activity logs
• Game play history, bet amounts, and game outcomes
• Cookies and similar tracking technologies (see Section 10)

3.4 Communications Data

• Records of your communications with 21jl customer support
• Feedback, complaints, and dispute records
• Marketing preferences and opt-in/opt-out records

4 How We Collect Data

We collect your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; payment confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank; fraud detection signals from security service providers.

5 How We Use Your Data

21jl uses your personal data only for legitimate, specified purposes. The table below summarizes the primary purposes for which we process your data and the corresponding legal basis for each:

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012 and applicable regulations, 21jl processes your personal data on the following legal bases:

• Contract performance: Processing necessary to fulfill our obligations to you under the 21jl Terms & Conditions, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC, AML, and responsible gaming obligations.
• Legitimate interest: Processing necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent, such as for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Sharing Your Data

21jl does not sell your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this policy:

7.1 Service Providers

We engage trusted third-party service providers to assist in operating the Platform, including KYC and identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), cloud hosting providers, fraud detection services, and customer support platforms. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data privacy laws.

7.2 Game Content Providers

Certain games on the 21jl Platform are provided by licensed third-party game studios. These providers may receive limited technical data (such as session tokens and bet data) necessary to deliver the game experience. They are not permitted to use this data for their own marketing or profiling purposes.

7.3 Regulatory and Law Enforcement Authorities

We may disclose your personal data to regulatory bodies, law enforcement agencies, or other government authorities where required to do so by applicable law, court order, or regulatory directive. This includes disclosures required under Philippine AML regulations.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 21jl's assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

8 Data Retention

21jl retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements.

As a general rule, account data and transaction records are retained for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations and applicable gaming regulations. Communications data is retained for three (3) years. Technical and usage data is retained for up to two (2) years.

Where data is retained solely on the basis of your consent (such as marketing preferences), it will be deleted promptly upon withdrawal of consent, unless another legal basis for retention applies.

When personal data is no longer required, it is securely deleted or anonymized in accordance with our internal data disposal procedures.

9 Data Security

21jl implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 21jl Platform.
• Encryption of sensitive data at rest, including financial information and government ID details.
• Role-based access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

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 data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant authorities as required by applicable law.

10 Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 21jl Platform. They help us recognize your device, remember your preferences, maintain your session, and analyze how the Platform is used.

10.2 Types of Cookies We Use

• Strictly necessary cookies: Required for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login state to improve your experience.
• Analytics cookies: Collect anonymized data about how players use the Platform to help us improve performance and usability.
• Marketing cookies: Used only with your consent to deliver relevant promotional content within the 21jl Platform.

10.3 Managing Cookies

You can control non-essential cookies through your browser settings or through the cookie preference center available on the Platform. Please note that disabling certain cookies may affect the functionality of the Platform.

11 Minors

The 21jl Platform is strictly intended for persons aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, 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 21jl Platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

12 Your Rights

Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights with respect to your personal data held by 21jl:

To exercise any of these rights, please submit a written request to [email protected]. We will respond within fifteen (15) business days. We may need to verify your identity before processing your request. Some rights are subject to limitations under applicable law, particularly where processing is required for legal compliance or fraud prevention purposes.

13 International Data Transfers

The 21jl Platform primarily stores and processes data within the Philippines. Where it is necessary to transfer your personal data to service providers or partners located outside the Philippines, 21jl will ensure that appropriate safeguards are in place to protect your data, including contractual data protection clauses consistent with the requirements of the Data Privacy Act of 2012.

By using the 21jl Platform, you acknowledge that your data may be transferred to and processed in countries outside the Philippines where data protection laws may differ from those in your home jurisdiction. We will always take steps to ensure your data receives an adequate level of protection regardless of where it is processed.

14 Changes to This Policy

21jl reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect, except where immediate changes are required by law or regulatory directive.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised policy.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 21jl, please contact our Data Protection Officer using the details below. We are committed to addressing all privacy-related inquiries promptly and transparently.

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that your data privacy rights have been violated. Information about the NPC and how to file a complaint is available through official Philippine government channels.