28jl Privacy Policy

This Privacy Policy ("Policy") describes how 28jl ("the Platform," "we," "us," or "our") collects, uses, stores, and protects the personal information of individuals ("you," "Player," or "User") who access or use the 28jl website at https://28jl.app and all associated services, games, mobile applications, and features offered therein.

28jl is committed to protecting the privacy and personal data of all registered players, particularly those based in the Philippines. This Policy is drafted in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

By accessing the 28jl platform, creating an account, or using any of our services, 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 any part of this Policy, you must discontinue use of the platform immediately.

For the purposes of the Data Privacy Act of 2012 and this Policy, 28jl acts as the Personal Information Controller in respect of the personal data you provide when registering and using the platform. As the data controller, 28jl determines the purposes and means by which your personal data is processed.

28jl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data privacy laws and this Policy. If you have any questions, concerns, or requests relating to your personal data, you may contact our DPO through the support channels listed in Section 13 of this Policy.

28jl 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:

28jl collects your personal data through the following primary channels:

• Direct Registration: When you create a 28jl account, you voluntarily provide identity and contact data through the registration form.
• KYC Verification: When you submit identity documents for account verification, we collect and store copies of those documents securely.
• Deposits & Withdrawals: When you conduct financial transactions on the platform, we collect the payment details necessary to process those transactions through GCash, PayMaya, BPI, BDO, or Metrobank.
• Gameplay Activity: Our platform automatically records game session data, wager history, and account activity as you use the platform.
• Customer Support: When you contact our support team via live chat or email, we collect and retain records of those communications.
• Cookies & Tracking Technologies: Our platform uses cookies and similar technologies to collect technical data about your device and browsing behavior. See Section 7 for full details.
• Third-Party Verification Services: In some cases, we may receive identity verification data from trusted third-party KYC service providers engaged to assist with regulatory compliance.

We do not collect personal data from you without a lawful basis for doing so, and we do not collect more data than is necessary for the stated purpose.

28jl processes your personal data only where we have a lawful basis to do so under the Data Privacy Act of 2012. The following table summarizes the primary purposes for which we process your data and the corresponding legal basis:

28jl does not sell, rent, or trade your personal data to any third party for commercial purposes. We share your personal data only in the following limited circumstances:

• Payment Processors: We share financial data with payment service providers (including GCash, PayMaya, and partner banks such as BPI, BDO, and Metrobank) solely to process your deposit and withdrawal transactions.
• KYC & Identity Verification Providers: We engage trusted third-party KYC service providers to assist with identity verification and age confirmation. These providers process your data only on our instructions and under strict confidentiality obligations.
• IT & Platform Service Providers: We share technical data with cloud hosting, cybersecurity, and platform infrastructure providers who support the operation of the 28jl platform. All such providers are bound by data processing agreements.
• Regulatory & Law Enforcement Authorities: We may disclose personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other Philippine government authorities where required by law or in response to a lawful request.
• Fraud Prevention Networks: We may share data with industry fraud prevention services to detect and prevent fraudulent activity, money laundering, and other illegal conduct.

All third parties with whom we share personal data are required to maintain the confidentiality and security of that data and to use it only for the specific purpose for which it was shared.

28jl uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and gather analytics data that helps us improve our services. A cookie is a small text file placed on your device when you visit our website.

The types of cookies we use include:

• Strictly Necessary Cookies: These cookies are essential for the platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Performance & Analytics Cookies: These cookies collect anonymized data about how players use the 28jl platform — such as which pages are visited most frequently and how long sessions last. This data helps us improve platform performance and user experience.
• Functional Cookies: These cookies remember your preferences and settings (such as language and display preferences) to provide a more personalized experience.
• Security Cookies: These cookies help us detect and prevent fraudulent activity, unauthorized account access, and other security threats.

In addition to cookies, we may use web beacons, pixel tags, and similar technologies to track user interactions with our platform and communications. All such technologies are used in accordance with this Privacy Policy.

28jl retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our internal data disposal procedures. Where data is anonymized, it may be retained indefinitely for statistical and analytical purposes as it can no longer be linked to any individual.

28jl implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• Encryption: All data transmitted between your device and the 28jl platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data stored in our systems — including financial account details and KYC documents — is encrypted at rest.
• Access Controls: Access to personal data within 28jl's systems is strictly limited to authorized personnel who require access to perform their job functions. All staff with access to personal data are subject to confidentiality obligations.
• Two-Factor Authentication: 28jl supports two-factor authentication (2FA) for player accounts to provide an additional layer of protection against unauthorized access.
• Regular Security Audits: Our platform undergoes regular security assessments and penetration testing conducted by independent cybersecurity professionals.
• Incident Response: 28jl maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

As a data subject under the Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by 28jl:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data where that processing is based on legitimate interest, including objecting to direct marketing communications.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

The 28jl platform is strictly intended for adults aged 21 years and above, in accordance with Philippine laws and regulations governing online gambling and casino-style gaming. 28jl does not knowingly collect personal data from any person under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data from our systems, close the associated account, and return any deposited funds at our discretion. Any winnings generated by an underage account will be forfeited.

We encourage parents and guardians to use parental control software and to monitor their children's online activity to prevent access to age-restricted gaming platforms.

28jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this Policy, we will notify registered players through one or more of the following methods: a prominent notice on the 28jl platform, an in-app notification, or an email to your registered email address. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 28jl, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the 28jl platform. This is the fastest way to reach our support team for urgent privacy concerns.
• Email: You may reach our Data Protection Officer at [email protected] — please include "Privacy Request" in the subject line.

All privacy-related inquiries will be acknowledged within five (5) business days. Formal data subject requests (access, rectification, erasure, etc.) will be processed within fifteen (15) business days of identity verification.

If you are not satisfied with our response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.