a39jl Privacy Policy

§1 About This Policy

This Privacy Policy ("Policy") is issued by a39jl ("we," "us," "our," "the Platform") and applies to all personal information collected from individuals ("you," "the Player," "the User") who access, register on, or otherwise interact with the a39jl website at https://a39jl.net and all related services, features, games, and content (collectively, the "Service").

a39jl is committed to safeguarding the privacy and personal data of all Filipino players and visitors. This Policy describes in plain, transparent terms what personal information we collect, the purposes for which we process it, with whom we share it, how long we retain it, and what rights you have over it under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its implementing rules and regulations.

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

§2 Data We Collect

a39jl collects personal information that is necessary to provide you with a safe, legal, and fully functional gaming experience. The categories of personal data we collect are outlined below:

2.1 Identity and Registration Data

• Full legal name as it appears on a government-issued ID
• Date of birth (for age verification — you must be 21 or older)
• Gender
• Nationality and country of residence
• Government-issued identification number (e.g., PhilSys ID, SSS, UMID, Passport, Driver's License)

2.2 Contact Information

• Email address
• Mobile phone number (used for OTP verification and 2FA)
• Residential address, city, and province (e.g., Manila, Cebu, Davao, Quezon City, Makati)

2.3 Financial and Payment Data

• GCash mobile number or Maya account details
• Bank account details for BPI, BDO, or other linked banks
• Deposit and withdrawal transaction history
• Source of funds declarations where required by anti-money laundering regulations

2.4 Gaming Activity Data

• Game session history, wager amounts, and game outcomes
• Bonus claims, promotional participation records, and wagering progress
• Responsible gaming tool settings, including deposit limits and self-exclusion status

2.5 Technical and Device Data

• IP address and geolocation data (country and region level)
• Device type, operating system, and browser version
• Session timestamps, login history, and access logs
• Cookie identifiers and analytics data (see Section 7)

2.6 Communications Data

• Records of your correspondence with a39jl customer support via live chat or email
• Feedback, survey responses, and complaint records
• Marketing preferences and communication opt-in/opt-out status

§3 How We Collect Your Data

a39jl collects personal data through the following channels:

3.1 Directly from You

The majority of your personal data is collected directly from you when you: register an a39jl account and complete the onboarding process; submit KYC identity verification documents; make a deposit or request a withdrawal; contact our customer support team; or respond to surveys and promotions on the platform.

3.2 Automatically During Your Use of the Service

When you access a39jl, certain technical data is collected automatically by our systems and by cookies and similar tracking technologies embedded in the platform. This includes your IP address, device identifiers, browser fingerprint, session duration, pages visited, and game interactions. See Section 7 for our full Cookies Policy.

3.3 From Third-Party Sources

a39jl may receive personal data about you from the following third-party sources:

• Payment providers such as GCash, Maya, BPI, and BDO — for transaction verification and fraud screening purposes.
• Identity verification service providers — for automated KYC document checks and biometric liveness verification.
• Anti-fraud and anti-money laundering screening databases — to check player details against watchlists and politically exposed persons (PEP) lists as required by Philippine law.
• Regulatory and law enforcement authorities — where disclosures to a39jl are made pursuant to a lawful order or regulatory obligation.

§4 How We Use Your Data

a39jl uses the personal data we collect for the following purposes:

a39jl does not use your personal data for automated decision-making that produces legal or similarly significant effects on you without human review, except where required by regulatory compliance systems operating under legal obligation.

§5 Legal Basis for Processing

Under the Philippine Data Privacy Act, a39jl processes your personal data on the following lawful bases:

• Consent: Where you have given clear, specific, and informed consent to the processing of your data for a particular purpose, such as receiving promotional emails or SMS notifications from a39jl.
• Performance of a Contract: Where processing is necessary to fulfill the a39jl Terms & Conditions you have entered into, such as creating and managing your account, processing your deposits, and paying out your winnings.
• Legal Obligation: Where processing is required for a39jl to comply with applicable Philippine law, including the Anti-Money Laundering Act (RA 9160), the Revised PAGCOR Online Gaming Regulations, and data breach notification obligations under the DPA.
• Legitimate Interests: Where processing is necessary for a39jl's legitimate business interests — such as fraud prevention, platform security, and service improvement — provided those interests are not overridden by your fundamental rights and freedoms as a data subject.

§6 Sharing Your Data

a39jl does not sell or rent your personal information to third parties. We share your data only in the following circumstances and only to the minimum extent necessary:

6.1 Service Providers and Data Processors

a39jl engages trusted third-party service providers to assist in operating the platform. These providers act as data processors under written agreements that prohibit them from using your data for any purpose beyond the specific service they provide to a39jl. Categories of service providers include:

• Payment processing partners (GCash, Maya, BPI, BDO, InstaPay, PesoNet)
• Identity verification and KYC platform providers
• Cloud hosting and server infrastructure providers
• Customer support software providers
• Fraud detection and risk management systems
• Analytics and platform performance monitoring tools

6.2 Regulatory and Law Enforcement Disclosures

a39jl may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Philippine National Police (PNP), or other competent Philippine authorities where required by law, court order, or regulatory directive. a39jl will notify affected players of such disclosures where permitted by applicable law.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of a39jl's business assets, player personal data may be transferred to the acquiring entity as part of that transaction. Affected players will be notified via email prior to any such transfer, and the receiving entity will be required to honor this Privacy Policy or provide equivalent protections.

§7 Cookies and Tracking Technologies

a39jl uses cookies and similar tracking technologies (including local storage objects and session tokens) to operate and improve the platform. Cookies are small text files stored on your device by your browser. The types of cookies we use are as follows:

7.1 Strictly Necessary Cookies

These cookies are essential for the a39jl platform to function correctly and cannot be switched off. They include session authentication tokens, CSRF protection tokens, and load balancing cookies. No personally identifiable information is stored in strictly necessary cookies beyond what is required to maintain your session.

7.2 Analytics Cookies

Analytics cookies allow a39jl to measure how the platform is used — including which pages are visited most frequently, how players navigate between game categories, and where technical errors occur. This data is aggregated and anonymized wherever possible. You may opt out of analytics cookies via your browser settings without affecting your ability to use the Service.

7.3 Functional Cookies

Functional cookies remember your preferences, such as your chosen language, display settings, and responsible gaming tool configurations. Disabling functional cookies may affect the personalization of your experience on a39jl but will not prevent access to core gaming features.

7.4 Marketing Cookies

With your explicit consent, a39jl may use marketing cookies to deliver personalized promotional content based on your activity on the platform. Marketing cookies are only activated where you have opted in to promotional communications. You may withdraw consent for marketing cookies at any time via your account settings or browser preferences.

§8 Data Retention

a39jl retains personal data for no longer than is necessary to fulfill the purposes for which it was collected, subject to the minimum retention periods required by Philippine law. Our standard retention periods are as follows:

• Active account data: Retained for the duration of your account relationship with a39jl plus five (5) years following account closure, in accordance with AMLC record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• KYC and identity verification documents: Retained for five (5) years following account closure or the date of the last transaction, whichever is later.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Analytics and session log data: Retained in aggregated or anonymized form for up to twenty-four (24) months.
• Marketing preference records: Retained until you withdraw consent or close your account.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC guidelines on data disposal.

§9 Data Security

a39jl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS 1.3): All data transmitted between your browser or mobile device and a39jl servers is encrypted using TLS 1.3 with 256-bit AES encryption.
• Database encryption at rest: Sensitive personal data stored in a39jl databases is encrypted at rest using industry-standard encryption algorithms.
• Access controls: Access to systems containing personal data is restricted to authorized a39jl personnel on a need-to-know basis, enforced through role-based access control (RBAC) and multi-factor authentication.
• Intrusion detection and monitoring: a39jl operates continuous security monitoring, intrusion detection systems, and automated alerting for anomalous access patterns.
• Regular penetration testing: The a39jl platform undergoes periodic independent security assessments and penetration tests to identify and remediate vulnerabilities.
• Incident response plan: a39jl maintains a documented personal data breach response plan. In the event of a breach likely to cause harm to affected players, we will notify both the National Privacy Commission and affected individuals within the timeframes prescribed by the DPA.

While a39jl takes all reasonable steps to protect your personal data, no internet-based service can guarantee absolute security. You are also responsible for maintaining the security of your own account credentials. Please review Section 4 of the a39jl Terms & Conditions for your account security obligations.

§10 Your Privacy Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal information held by a39jl. These rights are enforceable and may be exercised by submitting a written request to our Data Protection Officer at [email protected]:

a39jl will respond to all verified privacy rights requests within thirty (30) days of receipt, as required by the DPA. Where a request is complex or numerous, we may extend this period by a further thirty (30) days with prior notification. We may need to verify your identity before processing your request to prevent unauthorized disclosure of another person's data.

§11 Children and Minors

The a39jl platform is strictly intended for adults aged 21 years and above, in compliance with PAGCOR regulations governing online gambling in the Philippines. a39jl does not knowingly collect, process, or retain personal data from individuals under the age of 21.

If a39jl becomes aware that personal data has been collected from an individual under the age of 21, that account will be immediately suspended, the data will be flagged for deletion, and any deposits made will be returned to the originating payment method. Any winnings associated with an underage account will be voided.

If you are a parent or guardian and believe that a minor has created an a39jl account or provided personal information to the platform without your knowledge, please contact us immediately at [email protected] so that we may take prompt corrective action.

§12 International Data Transfers

a39jl's primary operations and data processing activities are conducted within the Philippines. However, some of our third-party service providers — particularly cloud infrastructure and analytics vendors — may process certain technical data on servers located outside the Philippines.

Where personal data is transferred internationally, a39jl ensures that such transfers are conducted in compliance with the cross-border data transfer provisions of the Philippine Data Privacy Act and applicable NPC guidelines. We apply appropriate safeguards including:

• Standard contractual clauses requiring the recipient to apply protections equivalent to those mandated by the DPA.
• Transfers only to jurisdictions assessed by the NPC as providing adequate levels of data protection.
• Data minimization practices ensuring that only the minimum data necessary for the specific service is transferred internationally.

For further information about international data transfers involving your personal data, please contact our Data Protection Officer.

§13 Changes to This Policy

a39jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this Policy, a39jl will notify registered players via email or via a prominent notice displayed on the a39jl platform prior to the changes taking effect. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data.

Your continued use of the a39jl platform following the effective date of any amendments constitutes your acceptance of the updated Privacy Policy. If you do not agree to the updated Policy, you must cease using the Service and may request account closure by contacting our support team.

§14 Contact and Data Protection Officer

a39jl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and for handling all privacy-related inquiries, requests, and complaints from players.

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or have a concern about how a39jl has handled your personal data, please contact us through the following channels:

If you are not satisfied with a39jl's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent regulatory authority responsible for enforcing the Data Privacy Act.