635jl Privacy Policy

01 Introduction & Scope

635jl ("635jl," "we," "us," "our") is an online gaming platform accessible at https://635jl.club. This Privacy Policy applies to all personal data collected, used, stored, or otherwise processed by 635jl in connection with the operation of the platform and the delivery of gaming, financial, and customer support services to Players registered in the Philippines and other jurisdictions where the platform is accessible.

This Policy should be read together with the 635jl Terms & Conditions, which govern the overall contractual relationship between 635jl and its Players. In the event of any conflict between this Privacy Policy and the Terms & Conditions with respect to data privacy matters, this Privacy Policy prevails.

635jl is committed to the principles of transparency, proportionality, and legitimate purpose embedded in the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission (NPC) of the Philippines.

02 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, 635jl is the Personal Information Controller in respect of personal data collected through the 635jl platform. This means 635jl determines the purpose and manner by which your personal data is collected and processed.

Where third-party service providers process personal data on behalf of 635jl — such as payment processors, game studio providers, or KYC verification services — those providers act as Personal Information Processors under agreements that require them to handle your data solely in accordance with 635jl's instructions and the requirements of the DPA.

635jl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy regulations. You may contact the 635jl DPO through the support channels described in Section 16 of this Policy.

03 Personal Data We Collect

635jl collects the following categories of personal data:

3.1 Identity Data

• Full legal name as it appears on a government-issued Philippine ID.
• Date of birth (used to verify 21+ age eligibility).
• Gender (optional, where provided during profile setup).
• Photographs or selfies submitted during KYC verification.
• Government-issued ID document data — including ID type, ID number, and document images — submitted during the Know Your Customer (KYC) process.

3.2 Contact Data

• Email address registered to the 635jl account.
• Philippine mobile number used for OTP registration and two-factor authentication.
• City of residence (optional, where provided).

3.3 Financial Data

• GCash mobile number, Maya account identifier, or bank account details used for deposits and withdrawals.
• Transaction history — deposit amounts, dates, payment methods, and withdrawal records.
• Cryptocurrency wallet addresses (where applicable).

3.4 Technical Data

• IP address at time of registration and login.
• Device type, operating system, and browser or app version.
• Login timestamps and session duration data.
• Cookies and similar tracking technologies (see Section 9).

3.5 Gaming & Behavioural Data

• Game history — titles played, wager amounts, wins, losses, and bonus activity.
• Responsible gaming settings and limit activity.
• Customer support interaction records.
• Promotional preference and opt-in data.

04 How We Collect Your Data

635jl collects personal data through the following means:

• Direct collection: When you register a 635jl account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions, you provide personal data directly to 635jl.
• Automated collection: When you access and use the 635jl platform, certain technical and behavioural data is collected automatically through server logs, cookies, and similar tracking technologies.
• Third-party sources: 635jl may receive data from payment processors (to confirm transaction completion), KYC service providers (for identity verification), and fraud prevention services — all subject to the terms of this Policy and applicable data sharing agreements.

05 Purposes of Processing

635jl processes your personal data for the following specific, explicit, and legitimate purposes:

1. Account registration and management — to create, maintain, and secure your 635jl account, including OTP verification and login authentication.
2. Age verification and KYC compliance — to verify that all Players are at least 21 years of age and to comply with applicable identity verification obligations.
3. Transaction processing — to process deposits and withdrawals via GCash, Maya, BPI, BDO, and other payment methods, and to maintain accurate financial records.
4. Gaming service delivery — to provide access to casino games, sports betting, bingo, and live dealer services, and to maintain game and wager records.
5. Customer support — to respond to enquiries, complaints, and account issues submitted to the 635jl support team.
6. Regulatory compliance and anti-money laundering — to fulfil obligations under Philippine gaming regulations, the Anti-Money Laundering Act (AMLA), and related legislation.
7. Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, account misuse, and security breaches.
8. Responsible gaming enforcement — to implement and monitor deposit limits, loss limits, self-exclusion orders, and other responsible gaming tools.
9. Marketing and promotions — where you have consented, to send promotional communications about 635jl offers, bonuses, and new game releases. You may withdraw marketing consent at any time through your account settings.
10. Platform improvement — to analyse usage patterns, troubleshoot technical issues, and improve the 635jl platform based on aggregated behavioural data.

635jl does not use your personal data for any purpose other than those described in this Policy without your prior explicit consent.

06 Legal Basis for Processing

Under the Data Privacy Act of 2012, 635jl relies on the following legal bases for processing your personal data:

• Contractual necessity: Processing required to deliver the services you have contracted for under the 635jl Terms & Conditions — including account management, deposits, withdrawals, and gaming service delivery.
• Legal obligation: Processing required to comply with applicable Philippine law — including KYC obligations, AMLA requirements, responsible gaming mandates, and PAGCOR-context regulatory requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and internal analytics that are necessary for 635jl's legitimate business interests and do not override your rights and freedoms.
• Consent: Processing for marketing communications and non-essential analytics, where you have given clear, informed, and voluntary consent. You may withdraw consent at any time.

07 Sharing Your Personal Data

635jl does not sell, rent, or trade your personal data to third parties. 635jl 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 Service Providers

Third-party companies that process data on 635jl's behalf, including: payment processors (GCash, Maya, BPI, BDO, and cryptocurrency processors), KYC and identity verification service providers, fraud detection and cybersecurity services, cloud infrastructure and data hosting providers, and customer support platform providers. All service providers are bound by data processing agreements requiring compliance with the DPA.

7.2 Game Studio Partners

Game studios providing titles available on 635jl — such as MG Live and other certified RNG providers — may receive session-level data (Player ID, wager amounts, game outcomes) necessary to operate and audit the games. Personally identifiable information beyond an anonymised Player ID is not shared with game studio partners.

7.3 Regulatory and Law Enforcement Authorities

Where required by applicable Philippine law, court order, or regulatory directive — including requests from PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine authorities — 635jl may disclose personal data without prior notice to the Player.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 635jl's assets, Player data may be transferred to the successor entity, subject to the same privacy protections as described in this Policy. Players will be notified of any such transfer through the platform or by email.

08 Data Retention

635jl retains personal data only for as long as necessary to fulfil the purposes for which it was collected, and in accordance with retention obligations under applicable Philippine law. The following general retention periods apply:

• Active accounts: Personal data is retained for the lifetime of your 635jl account and for a period of five (5) years following account closure, consistent with AMLA record-keeping requirements.
• Transaction records: Financial transaction data — including deposit and withdrawal records — is retained for a minimum of five (5) years from the date of the transaction, consistent with AMLC guidelines.
• KYC documents: Identity verification documents are retained for five (5) years from account closure or the end of the customer relationship.
• Marketing data: Where processing is based on consent, marketing-related data is retained until consent is withdrawn and for a reasonable period thereafter to evidence the consent and its withdrawal.
• Technical logs: Server logs and session data are retained for up to 12 months for security and fraud investigation purposes.

At the end of the applicable retention period, 635jl will securely delete or anonymise your personal data in a manner consistent with industry-standard data destruction practices.

09 Cookies & Tracking Technologies

635jl uses cookies and similar web tracking technologies on the 635jl platform. A cookie is a small text file placed on your device by the platform when you visit. Cookies serve the following purposes on 635jl:

• Essential cookies: Necessary for the platform to function — including maintaining your login session, remembering your account settings, and enabling secure transactions. These cannot be disabled without affecting platform functionality.
• Analytical cookies: Used to understand how Players use the platform — including pages visited, session duration, and navigation patterns — to improve the 635jl experience. This data is aggregated and does not identify individual Players.
• Functional cookies: Used to remember your preferences — such as language settings and responsible gaming tool configurations — across sessions.
• Security cookies: Used to detect and prevent fraudulent activity, including recognising trusted devices and flagging unusual login behaviour for further authentication.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will impair your ability to use the 635jl platform. 635jl does not use cookies to serve third-party advertising or to track your activity on external websites.

10 Security Measures

635jl implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 635jl's servers.
• Encrypted storage for sensitive personal and financial data at rest.
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis.
• Multi-factor authentication requirements for all 635jl staff accessing systems that process Player data.
• Intrusion detection and monitoring systems scanning for unauthorised access attempts.
• Regular third-party security audits and penetration testing of the platform.
• Incident response procedures for identifying, containing, and reporting personal data breaches.

Notwithstanding these measures, no internet-based system can guarantee absolute security. Players are encouraged to use strong, unique passwords, enable two-factor authentication on their 635jl accounts, and report any suspected unauthorised access to 635jl support immediately.

11 International Data Transfers

Some of 635jl's service providers — including cloud infrastructure providers and game studio partners — may be located in countries outside the Philippines. Where personal data is transferred outside the Philippines, 635jl takes appropriate steps to ensure that an adequate level of data protection is maintained, including:

• Requiring the recipient to be located in a country recognised by the NPC as providing adequate data protection.
• Entering into data processing agreements that impose data protection obligations equivalent to those under Philippine law.
• Implementing standard contractual clauses approved by the NPC where no adequacy decision is in place.

By using the 635jl platform, you acknowledge and consent to the transfer of your personal data to service providers outside the Philippines where necessary for the delivery of 635jl's services, subject to the safeguards described above.

12 Your Data Subject Rights

Under the Data Privacy Act of 2012 and applicable NPC regulations, you have the following rights with respect to your personal data held by 635jl:

To exercise any of your data subject rights, please contact the 635jl Data Protection Officer via the support channels described in Section 16. 635jl will respond to valid data subject requests within 30 calendar days of receipt, consistent with NPC guidelines.

13 Children & Minors

The 635jl platform is strictly restricted to individuals who are at least 21 years of age. 635jl does not knowingly collect, process, or store personal data belonging to individuals under the age of 21.

Where 635jl discovers or has reason to believe that a registered account belongs to a person under the age of 21, that account will be suspended immediately, all associated gaming activity will be voided, all deposited funds will be returned to the originating payment method, and any collected personal data will be securely deleted in accordance with applicable data retention obligations.

If you are a parent or guardian and believe your child has registered for a 635jl account, please contact 635jl support immediately at [email protected]. 635jl will take prompt action to investigate and close the account.

14 Third-Party Links

The 635jl platform does not contain links to third-party websites. All links on the platform direct to internal 635jl pages only. This Privacy Policy does not extend to any third-party services you access independently — such as your GCash or Maya application, your bank's online portal, or any social media platform. 635jl is not responsible for the privacy practices or content of any third-party services.

15 Changes to This Privacy Policy

635jl reserves the right to update or amend this Privacy Policy at any time. Where changes are material — for example, where 635jl introduces a new purpose for processing, or begins sharing data with a new category of third parties — 635jl will provide advance notice through the platform or by email to your registered address before the changes take effect.

The date of the most recent update to this Policy is displayed at the top of this page. We encourage you to review this Policy periodically. Continued use of the 635jl platform following the effective date of any amendment constitutes acceptance of the revised Policy.

16 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise a data subject right, or wish to raise a concern about 635jl's data processing practices, please contact the 635jl Data Protection Officer through any of the following channels:

• In-platform Live Chat: Available 24/7 via your 635jl account — select "Privacy & Data" from the support category menu.
• Email: [email protected] — please use the subject line "Data Privacy Request" and include your registered email address and the nature of your request.

635jl will acknowledge all data privacy enquiries within 72 hours and aim to resolve them fully within 30 calendar days. For complex data subject requests, 635jl may request additional identity verification before processing the request, to protect your data from unauthorised third-party access.

16.1 National Privacy Commission

If you are not satisfied with 635jl's response to a data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the independent body responsible for overseeing compliance with the Data Privacy Act of 2012. Contact information for the NPC is available through official Philippine government channels.