38JL Privacy Policy

1. What Information We Collect

38JL collects personal information from you at different points during your use of the platform. Below is a breakdown of what we collect and when.

We do not collect sensitive personal information such as religion, political opinions, or health data. We do not store full payment card numbers — card-based payments are not supported on 38JL. Cryptocurrency is also not accepted, so no wallet addresses are collected.

2. How We Use Your Information

Your personal data is used only for the following purposes:

• Account creation and management — setting up and maintaining your 38JL player account, including storing your preferences and account settings.
• Identity verification — confirming that you meet the 21+ age requirement and that withdrawal requests are processed to the account holder's own payment method.
• Transaction processing — crediting deposits to your balance and processing withdrawal requests to your registered Philippine e-wallet or bank account.
• Security and fraud prevention — detecting unusual login patterns, flagging suspicious transactions, and protecting your account from unauthorised access.
• Platform improvement — using aggregated, anonymised session and behaviour data to identify technical issues and improve the player experience.
• Customer support — reviewing your account history and prior communications to resolve queries or complaints efficiently.
• Legal compliance — retaining records as required by applicable Philippine financial and data protection regulations.

We do not use your personal data for automated profiling that produces legal effects or similarly significant decisions without human review.

3. Data Sharing and Disclosure

38JL does not sell your personal information. We share your data only in the limited circumstances described below:

• Payment processors — to complete deposit and withdrawal transactions, we pass necessary details (such as your name and account reference) to the relevant Philippine payment provider. These partners process your data solely to complete the transaction.
• Game providers — certain technical session data (such as a session token and game round ID) is passed to the game software provider to load and run games. No sensitive personal data is shared with game providers beyond what is technically required.
• Identity verification services — when you submit KYC documents, they are processed through a secure verification service to confirm authenticity. Your documents are not retained by the verification partner beyond the period needed to complete the check.
• Legal and regulatory requirements — we may disclose your data to government authorities or law enforcement if required by applicable Philippine law, a valid court order, or a lawful regulatory request. We will notify you where we are permitted to do so.

All third parties who handle your data on our behalf are required to maintain appropriate security standards and to use your information only for the purpose for which it was shared.

4. How We Protect Your Data

Keeping your data secure is a core responsibility for 38JL. We apply the following technical and operational measures:

• SSL/TLS encryption on all data transmitted between your device and our servers, whether you access 38JL via browser or the mobile app.
• Encrypted storage for sensitive data fields, including passwords (which are hashed and never stored in plain text) and identity document references.
• OTP-based verification for high-risk actions such as password changes, new device logins, and withdrawal requests, adding a second layer of authentication beyond your password.
• Access controls within our internal systems that limit staff access to personal data on a need-to-know basis.
• Monitoring and logging of account activity to detect unusual patterns that may indicate unauthorised access or fraudulent behaviour.

Despite these measures, no online platform can guarantee absolute security. You also play a role in keeping your account safe — use a strong, unique password, do not share your OTP codes with anyone, and log out when using shared devices.

5. Data Retention

We keep your personal data for as long as your account is active and for a reasonable period after closure, as required by applicable law. Specific retention practices include:

• Account and identity records are retained for the duration of your account and for a period thereafter as required by Philippine financial record-keeping obligations.
• Transaction records (deposit and withdrawal history) are retained in line with applicable regulatory requirements for financial records.
• Support communications are retained for a period sufficient to resolve ongoing disputes and to respond to any follow-up queries.
• KYC documents are retained for the minimum period required to satisfy applicable verification and anti-money laundering obligations.

When data is no longer required for its original purpose and no legal retention obligation applies, it is securely deleted or anonymised. Anonymised and aggregated data (from which no individual can be identified) may be retained indefinitely for platform analytics and improvement.

6. Your Rights as a Data Subject

Under applicable Philippine data privacy law, you have the following rights with respect to your personal information held by 38JL:

• Right to be informed — you have the right to know what personal data we hold about you and how it is used. This Privacy Policy fulfils that obligation.
• Right of access — you can request a copy of the personal data we hold on your account at any time by contacting support.
• Right to correction — if any of your personal data is inaccurate or out of date, you can request that it be corrected. You can update basic contact details directly from your account settings.
• Right to erasure — you may request deletion of your personal data. This right is subject to legal obligations that may require 38JL to retain certain records even after account closure.
• Right to object — you can object to the processing of your data for certain purposes, such as receiving promotional communications.
• Right to data portability — you may request your data in a structured, commonly used format where this is technically feasible.

To exercise any of these rights, contact the 38JL support team using the email address in the footer. We aim to respond to all data subject requests within a reasonable timeframe. Where a request cannot be fulfilled in full (for example, due to a legal retention requirement), we will explain the reason.

7. Cookies and Tracking

38JL uses cookies and similar technologies to keep the platform running smoothly and to understand how players use it. Here is what we use and why:

• Essential cookies — required for the platform to function. These include session cookies that keep you logged in during a visit and security tokens that protect against cross-site request forgery. You cannot opt out of these without affecting your ability to use the platform.
• Functional cookies — store your preferences such as language settings and display options so you do not need to re-enter them each visit.
• Analytics cookies — collect anonymised data about how the platform is navigated (pages visited, time on site, errors encountered) to help us improve the user experience. This data is not linked to individual accounts.

We do not use third-party advertising or cross-site tracking cookies. No cookies are used to build advertising profiles or track your activity outside of the 38JL platform.

Most browsers allow you to view, manage, and delete cookies through their settings. Disabling essential cookies will affect platform functionality, but you can safely decline or clear analytics and functional cookies without being locked out of your account.

8. Minors and Age Restrictions

38JL is strictly for individuals aged 21 and above. We do not knowingly collect personal information from anyone under the age of 21. If we become aware that a registered account belongs to a person under the minimum age, the account will be closed immediately and any data collected will be deleted in accordance with applicable law.

If you are a parent or guardian and believe a minor in your household has registered an account with 38JL, please contact our support team immediately. We will investigate and close the account promptly.

9. Changes to This Policy

38JL may update this Privacy Policy from time to time to reflect changes in the platform, applicable law, or our internal practices. When we make material changes, we will notify registered players via email or an in-platform notice before the updated policy takes effect.

The "Last updated" date at the top of this page always reflects the most recent revision. Continuing to use 38JL after a policy update constitutes acceptance of the revised terms.

We encourage you to review this page periodically. If you have any concerns about a change to our privacy practices, contact support before continuing to use the platform.