47JL Privacy
Policy

1. Introduction

47JL ("the Platform," "we," "us," "our") is committed to protecting the privacy and personal data of every player who uses our online gaming services. This Privacy Policy describes our practices regarding the collection, use, storage, and disclosure of personal information in connection with your use of the 47JL website, mobile application, and all associated services.

This policy is written 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. We take our obligations under Philippine data protection law seriously, and this document is intended to give you a clear, honest account of how your data is handled on the 47JL platform.

This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

For the purposes of applicable data protection legislation, 47JL is the data controller responsible for the personal information collected through the platform. As data controller, 47JL determines the purposes and means by which your personal data is processed.

If you have any questions about how your personal data is handled, or wish to exercise any of your data rights, you may contact our Data Protection Officer directly at:

Email: [email protected]

Please include "Data Privacy Request" in the subject line of your correspondence to ensure your query is directed to the appropriate team.

3. Data We Collect

47JL collects personal data that is necessary for the operation of the platform, compliance with legal obligations, and the delivery of a safe and personalized gaming experience. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID)
• Proof of residential address (e.g., utility bill, bank statement)
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account, bank statement)
• Selfie or live photo for identity confirmation where required

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash account reference, BPI or BDO account details — stored in tokenized or reference form only)
• Account balance history
• Bonus and promotion redemption records

3.4 Gaming Activity Data

• Game session records, including games played, wager amounts, and outcomes
• Sports betting history
• Loyalty Points earned and redeemed
• Tournament participation and results

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session timestamps and duration
• Cookies and similar tracking technology identifiers
• Referring URL and navigation path within the platform

3.6 Communications Data

• Support chat transcripts and email correspondence
• Feedback, complaints, and dispute records
• Marketing preference settings

4. How We Collect Data

47JL collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or update your account settings.
• Automatically — through cookies, web beacons, and similar tracking technologies when you access and navigate the platform.
• From third-party payment providers — such as GCash, PayMaya, BPI, BDO, and Metrobank, in connection with deposit and withdrawal processing.
• From identity verification service providers — who assist 47JL in confirming the authenticity of KYC documents.
• From fraud prevention and AML screening services — which may cross-reference your data against watchlists and databases maintained for regulatory compliance purposes.

5. How We Use Your Data

47JL uses the personal data we collect for the following purposes:

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 permitted by applicable law.

6. Legal Basis for Processing

47JL processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity — processing required to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and game delivery.
• Legal obligation — processing required to comply with applicable Philippine laws and regulations, including KYC requirements, AML obligations, and regulatory reporting duties.
• Legitimate interests — processing carried out for 47JL's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent — processing based on your freely given, specific, and informed consent, such as for marketing communications. You may withdraw consent at any time by updating your preferences in your account settings or by contacting support.

7. Data Sharing & Disclosure

47JL does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

7.1 Payment Service Providers

We share transaction-related data with payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank to facilitate deposits and withdrawals. These providers process your data under their own privacy policies and are bound by applicable financial regulations.

7.2 Identity Verification & KYC Providers

We engage third-party KYC and identity verification services to assist in confirming player identities and screening against AML watchlists. These providers act as data processors under contract with 47JL and are prohibited from using your data for any other purpose.

7.3 Technology & Infrastructure Providers

We use cloud hosting, data storage, and platform infrastructure providers who may process personal data on our behalf. All such providers are bound by data processing agreements that require them to maintain appropriate security standards.

7.4 Game Content Providers

Certain game titles on the 47JL platform are provided by third-party game studios. Limited technical data (such as session tokens and game round identifiers) may be shared with these providers for the purpose of game delivery and dispute resolution. No personally identifiable information beyond what is strictly necessary is shared.

7.5 Regulatory & Law Enforcement Authorities

47JL may disclose personal data to competent Philippine regulatory authorities, law enforcement agencies, or courts where required to do so by law, court order, or regulatory directive. We will notify affected players of such disclosures where legally permitted to do so.

8. Cookies & Tracking Technologies

47JL uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and support security functions. The types of cookies we use include:

• Strictly necessary cookies — essential for the platform to function, including session management, login authentication, and security tokens. These cannot be disabled.
• Functional cookies — used to remember your preferences such as language settings, display options, and game history for a more personalized experience.
• Analytics cookies — used to collect aggregated, anonymized data about how players navigate and use the platform, helping us identify areas for improvement.
• Security cookies — used to detect and prevent fraudulent activity, bot access, and unauthorized login attempts.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 47JL platform. A full cookie management interface is available within your account settings.

9. Data Retention

47JL retains personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Active account data — retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements.
• KYC and identity documents — retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Transaction records — retained for a minimum of five (5) years in accordance with financial record-keeping obligations.
• Support communications — retained for three (3) years from the date of the last interaction.
• Marketing data — retained until you withdraw consent or for a maximum of two (2) years from your last interaction with a marketing communication, whichever comes first.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 47JL's data disposal procedures.

10. Data Security

47JL implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 47JL platform
• AES-256 encryption for sensitive data stored at rest, including KYC documents and payment references
• Multi-factor authentication options for player accounts
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis
• Regular security audits, vulnerability assessments, and penetration testing
• 24/7 monitoring for suspicious activity, unauthorized access attempts, and data anomalies
• Incident response procedures for detecting, reporting, and managing personal data breaches

11. Your Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 47JL:

• Right to be informed — you have the right to know what personal data we collect, how we use it, and with whom we share it. This Privacy Policy fulfills that obligation.
• Right of access — you may request a copy of the personal data we hold about you at any time.
• Right to rectification — you may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure — you may 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 — you may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability — you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint — you have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of the above rights, please contact us at [email protected] with the subject line "Data Privacy Request." We will respond to all verified requests within thirty (30) days of receipt, in accordance with the Data Privacy Act of 2012.

Please note that certain rights may be subject to limitations where processing is required for compliance with legal obligations or the establishment, exercise, or defense of legal claims.

12. Children & Minors

The 47JL platform is strictly intended for individuals who are 21 years of age or older. 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 minor, 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 47JL platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

13. Third-Party Services

The 47JL platform may integrate with or link to third-party services, including payment gateways and game content providers. These third parties operate under their own privacy policies, and 47JL is not responsible for the data practices of third-party services beyond the contractual obligations we impose on them as data processors.

We encourage you to review the privacy policies of any third-party payment providers you use in connection with your 47JL account, including GCash, PayMaya, BPI, BDO, and Metrobank, to understand how they handle your financial data.

14. Policy Amendments

47JL reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via email or a prominent notice on the platform at least seven (7) days before taking effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. Your continued use of the 47JL platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy.

15. Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way 47JL handles your personal data, please contact our Data Protection Officer:

Email: [email protected]

Please use the subject line "Data Privacy Request" and include your registered username and a clear description of your query. We aim to acknowledge all privacy-related correspondence within 72 hours and to resolve substantive requests within 30 days.

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