Privacy Policy

This Policy applies to all personal data processed by 38jl in connection with the operation of the online gaming platform available at 38jl.club, including all associated features such as the player Account dashboard, wallet and payment functions, game interfaces, bonus and promotions system, customer support services, and responsible gaming tools.

For the purposes of this Policy, 38jl acts as the data controller in respect of personal data collected from registered Players and site visitors. As data controller, 38jl determines the purposes for which and the means by which personal data is processed.

This Policy applies to all users of the 38jl Platform globally, including Filipino players based in Manila, Cebu, Davao, Quezon City, Makati, and all other cities and regions across the Philippines, as well as international users accessing the Platform where permitted.

38jl collects personal data in several categories, depending on the nature of your interaction with the Platform. The categories below represent all personal data currently collected by 38jl:

38jl collects personal data through the following methods:

• Directly from you: Information you voluntarily provide during account registration, KYC verification, deposit and withdrawal requests, support communications, and responsible gaming tool configuration.
• Automatically during platform use: Technical data including IP address, device identifiers, browser data, and session information are collected automatically when you access the 38jl Platform via cookies, server logs, and similar technologies (see Section 6 — Cookies).
• From payment processors: When you conduct a financial transaction via GCash, Maya, BPI, BDO, Metrobank, 7-Eleven CLiQQ, USDT TRC20, or Coins.ph, the relevant payment processor may share transaction confirmation data with 38jl to enable wallet crediting and withdrawal processing.
• From identity verification services: Where 38jl uses a third-party KYC verification provider to assist with identity checks, that provider may return a verification result and associated data to 38jl.
• From fraud and AML screening services: 38jl may receive risk signals or flagging data from third-party fraud detection or anti-money laundering screening tools used to protect the integrity of the Platform.

38jl processes personal data for specific, identified purposes only. The table below sets out each processing purpose and the legal basis on which 38jl relies for that processing:

Where 38jl relies on legitimate interest as a legal basis, it has conducted a balancing assessment to confirm that the legitimate interest pursued by 38jl does not override your interests or fundamental rights. You may request details of any such assessment by contacting 38jl support.

38jl does not sell, rent, or trade your personal data to any third party for that party's own commercial or marketing purposes. Your data is only shared in the following limited and specific circumstances:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, 7-Eleven (ECPay), and other payment networks receive the minimum transactional data necessary to process your deposits and withdrawals. These processors operate under their own privacy policies and are bound by their respective regulatory obligations.
• KYC and identity verification providers: Where 38jl uses a third-party service to perform identity verification, your KYC documents and personal identifiers are shared with that provider under a data processing agreement that restricts secondary use of your data.
• Game content providers: Game providers such as JILI, Pragmatic Play, PG Soft, and others may receive anonymised or pseudonymised session data necessary for game round settlement and RTP calculation. They do not receive personally identifying information beyond what is technically required for game delivery.
• Anti-fraud and AML service providers: Third-party fraud detection and anti-money laundering screening tools may process transaction data and device identifiers as part of 38jl's compliance obligations.
• Regulatory authorities and law enforcement: 38jl may be legally required to disclose personal data to PAGCOR, Philippine law enforcement agencies, tax authorities, or other governmental bodies where mandated by applicable law, regulation, court order, or legal process.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by 38jl may access personal data on a need-to-know basis and are bound by confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of assets involving 38jl, player data may be transferred to the acquiring or successor entity, subject to the same privacy protections outlined in this Policy.

The 38jl Platform uses cookies and similar tracking technologies to maintain your login session, remember your preferences, and analyse platform usage. The following categories of cookies are used:

You can manage browser cookie settings through your browser's preferences (in Chrome: Settings → Privacy → Cookies; in Safari: Settings → Safari → Block Cookies). Note that disabling essential cookies will prevent you from logging into the 38jl Platform or using the wallet. 38jl does not use third-party advertising cookies or cross-site behavioural tracking technologies.

38jl retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply as a general guide:

• Account and registration data: Retained for the duration of the active account relationship, plus a minimum of five (5) years following account closure, to satisfy AML record-keeping requirements.
• KYC documentation: Retained for a minimum of five (5) years from the date of verification, in accordance with anti-money laundering regulations. KYC documents may be retained for a longer period where required by a specific regulatory obligation or legal proceeding.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required for financial audit and regulatory compliance purposes.
• Gaming activity logs: Retained for a minimum of three (3) years to support responsible gaming monitoring, dispute resolution, and regulatory reporting.
• Customer support communications: Retained for two (2) years from the date of the last communication in a support thread.
• Technical and device data: Server logs retained for up to ninety (90) days for security monitoring and fraud investigation purposes. Aggregated analytics data may be retained indefinitely in anonymised form.
• Marketing preference records: Retained until you withdraw consent or until your Account is closed, whichever comes first.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. If a legal hold or regulatory investigation is in progress at the point of scheduled deletion, data will be preserved until the hold is lifted.

38jl implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, or alteration. The following security measures are in place:

• TLS 1.3 encryption: All data in transit between your device and 38jl servers is encrypted using TLS 1.3, preventing interception of login credentials, payment data, and personal details.
• Password hashing: Player passwords are stored exclusively as salted cryptographic hashes. Plain-text passwords are never stored anywhere within the 38jl infrastructure.
• Access controls: Internal access to personal data is restricted on a need-to-know basis. Employees and contractors who access personal data are subject to confidentiality obligations and receive data protection training.
• KYC document security: Identity documents are stored in an access-controlled, encrypted document repository with audit logging. Access to KYC documents is limited to authorised compliance personnel only.
• Infrastructure security: 38jl's server infrastructure is hosted in data centres with physical security controls, redundancy, and regular security auditing.
• Brute force and intrusion protection: Automated systems monitor for and block repeated failed login attempts, credential stuffing attacks, and other patterns indicative of unauthorised access attempts.

Depending on the jurisdiction from which you access the 38jl Platform and the applicable data protection law, you may have some or all of the following rights in respect of your personal data held by 38jl:

To exercise any of the above rights, please submit a written request to the 38jl support team via live chat or by email to the address in Section 14 of this Policy. 38jl will acknowledge your request within a reasonable period and respond substantively as soon as practicable, and in any event within the timeframe required by applicable law. We may need to verify your identity before fulfilling a data rights request.

38jl does not knowingly collect personal data from individuals under the age of 21. The registration process requires confirmation of date of birth, and KYC verification includes age verification through government-issued identification. If 38jl discovers that personal data of a minor has been collected without proper age verification, the Account will be immediately suspended and the data will be deleted or returned, subject to any applicable legal retention requirement.

If you are a parent or guardian and believe that a person under the age of 21 has registered an Account on 38jl using false information, please contact 38jl support immediately via live chat so that the Account can be investigated and closed promptly.

38jl processes gaming activity and responsible gaming data for the specific purpose of protecting player welfare. This includes monitoring gaming patterns that may indicate problematic behaviour, delivering responsible gaming notifications, enforcing player-set limits, and administering self-exclusion requests.

Data processed for responsible gaming purposes is handled with particular sensitivity. Responsible gaming records, including self-exclusion status, are not accessible to promotional marketing teams and are not used to target excluded players with promotional communications. Self-exclusion records are retained beyond account closure to prevent re-registration during the exclusion period.

Players who wish to discuss their responsible gaming data, request a summary of their gaming history, or activate responsible gaming tools should visit the 38jl Responsible Gaming page or contact live chat support directly. 38jl processes responsible gaming data on the basis of legitimate interest in player protection and, where applicable, legal obligation under applicable gaming regulations.

The 38jl Platform does not contain outbound links to third-party websites beyond those necessary for game content delivery. In the event that any third-party content or service is accessible through the Platform, 38jl does not control and is not responsible for the privacy practices of those third parties.

Payment processors accessed in connection with deposits and withdrawals (GCash, Maya, BPI, BDO, Metrobank, 7-Eleven CLiQQ, USDT TRC20, Coins.ph) operate under their own privacy policies. 38jl encourages Players to review the privacy policies of all payment services they use in connection with their 38jl account.

38jl reserves the right to amend this Privacy Policy at any time. Where an amendment is material — meaning it meaningfully changes how your personal data is collected, used, or shared — 38jl will provide notice to registered Players through a notification upon login or by direct communication via your registered contact details.

The effective date and version number at the top of this document reflect the most current version of the Policy. Continued use of the 38jl Platform following a material amendment constitutes your acceptance of the revised Policy. If you do not accept an amendment, you may close your Account before the amendment takes effect.

For all privacy-related queries, data rights requests, or concerns about how 38jl processes your personal data, please contact the 38jl team through the following channel:

When submitting a data rights request, please provide: your registered username, the specific right you wish to exercise, and sufficient identifying information to allow us to verify your identity and locate your account. For security reasons, do not include your password or OTP in any email or support communication with 38jl.