23jl Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by 23jl ("the Platform," "we," "us," or "our") and applies to all personal information collected through the 23jl website, mobile platform, customer support channels, and any other touchpoints through which you interact with 23jl services.

23jl operates under PAGCOR regulation and is committed to handling all personal data in accordance with applicable Philippine privacy law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. As a PAGCOR-licensed platform, 23jl is also subject to data handling standards prescribed by the National Privacy Commission of the Philippines.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together govern your relationship with the 23jl Platform.

2. Information We Collect

2.1 Information You Provide Directly

When you register on 23jl, deposit funds, request withdrawals, contact support, or participate in promotions, you may provide us with the following categories of personal information:

• Identity information: full legal name, date of birth, nationality, and gender;
• Contact information: Philippine mobile number, email address, and residential address;
• Identity verification documents: scanned copies of government-issued Philippine IDs (passport, driver's licence, SSS ID, UMID, PhilHealth ID, or similar);
• Financial information: GCash account number, PayMaya account, BPI/BDO/Metrobank account details (masked), and Visa/Mastercard card details (tokenized, not stored in full by 23jl);
• Communication records: messages you send to 23jl via live chat, email, or any other support channel.

2.2 Information Collected Automatically

When you access and use the 23jl Platform, we automatically collect certain technical and behavioural data, including:

• IP address and approximate geographic location;
• Device type, operating system, browser type and version;
• Pages visited, features accessed, and time spent on each section of the Platform;
• Game session data, including wagers placed, game outcomes, and session duration;
• Login timestamps and session history;
• Referral source (how you arrived at the 23jl Platform).

2.3 Information from Third Parties

23jl may receive information about you from third-party payment processors (such as GCash or PayMaya) in connection with transaction processing, from identity verification service providers during KYC procedures, and from fraud prevention and anti-money laundering (AML) screening services as required by PAGCOR regulations.

3. How We Use Your Information

23jl uses the personal information we collect for the following purposes:

• Account management: to create, maintain, and administer your 23jl player account;
• Identity verification (KYC): to verify your identity and age (21+ requirement) in compliance with PAGCOR regulations;
• Payment processing: to process deposits, withdrawals, and bonus payments through your chosen Philippine payment method;
• Fraud prevention and AML compliance: to detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct;
• Customer support: to respond to your enquiries, resolve account issues, and communicate important account information;
• Regulatory compliance: to fulfil our obligations under PAGCOR licensing conditions, the Data Privacy Act of 2012, and other applicable Philippine laws;
• Platform improvement: to analyse usage patterns and improve the performance, security, and user experience of the 23jl Platform;
• Responsible gaming: to monitor gaming behaviour and proactively offer responsible gaming support where patterns suggest potential problem gambling;
• Promotions: to administer bonuses, tournaments, and promotional offers for which you have opted in.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 23jl processes your personal information on the following legal bases:

• Contractual necessity: processing required to perform our contract with you (account creation, payment processing, game access);
• Legal obligation: processing required to comply with PAGCOR licensing conditions, AML laws, and other applicable Philippine regulations;
• Legitimate interests: processing for fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights;
• Consent: processing for marketing communications, where you have provided explicit opt-in consent. You may withdraw consent at any time by contacting 23jl support.

5. Sharing Your Information

23jl shares your personal information only where necessary and only with the following categories of recipients:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard — shared only to the extent required to process your transactions;
• KYC and identity verification providers: third-party services that assist 23jl in verifying player identities in accordance with PAGCOR requirements;
• AML and fraud screening services: service providers that assist 23jl in detecting and preventing financial crime;
• Game content providers: game studios and live dealer platform operators whose games are accessible through 23jl — they receive anonymised session data for game performance purposes only;
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies where disclosure is required by law or court order;
• Professional advisors: legal, audit, and compliance advisors bound by professional confidentiality obligations.

All third-party service providers with whom 23jl shares personal data are contractually bound to handle such data securely, use it only for the specified purpose, and comply with applicable Philippine data protection laws.

6. Data Retention

23jl retains your personal information for as long as your account remains active and for a period thereafter as required by applicable law and PAGCOR regulations. Specifically:

• Account and identity records are retained for a minimum of five (5) years following account closure, as required by Philippine AML regulations;
• Transaction records are retained for a minimum of five (5) years from the date of each transaction;
• Customer support communications are retained for two (2) years from the date of the communication;
• Technical log data (IP addresses, session logs) is retained for up to twelve (12) months for security and fraud investigation purposes.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised in a manner that prevents re-identification.

7. Cookies & Tracking Technologies

The 23jl Platform uses cookies and similar tracking technologies to deliver and improve the Platform experience. Cookies are small data files stored on your device that allow 23jl to recognise your browser, remember your preferences, and analyse Platform usage.

Types of cookies used by 23jl:

• Essential cookies: required for basic Platform functionality, including maintaining your login session and processing transactions. These cannot be disabled without impairing Platform use;
• Analytics cookies: used to understand how players navigate the Platform, which features are most used, and where performance improvements are needed. Data collected is aggregated and anonymised;
• Preference cookies: used to remember your language, display, and notification preferences across sessions.

You can manage cookie preferences through your browser settings. Disabling essential cookies will affect Platform functionality. 23jl does not use advertising or cross-site tracking cookies.

8. Data Security

23jl implements comprehensive technical and organisational security measures to protect your personal information from unauthorised access, disclosure, alteration, or destruction. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 23jl Platform;
• Encrypted storage of sensitive personal and financial data at rest;
• Two-factor authentication (OTP via Philippine mobile number) for account access;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Continuous security monitoring and intrusion detection systems;
• Regular third-party security audits and penetration testing.

9. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal information held by 23jl:

• Right to be informed: you have the right to know what personal information 23jl holds about you and how it is being processed;
• Right of access: you may request a copy of the personal information 23jl holds about you at any time;
• Right to rectification: you may request correction of inaccurate or incomplete personal information;
• Right to erasure: you may request deletion of your personal information where it is no longer necessary for the purposes for which it was collected, subject to 23jl's legal retention obligations;
• Right to data portability: you may request that 23jl provide your personal information in a structured, commonly used, machine-readable format;
• Right to object: you may object to the processing of your personal information for direct marketing purposes at any time;
• Right to lodge a complaint: you have the right to file a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact 23jl's data privacy team using the contact details in Section 13 of this Policy. 23jl will respond to all privacy rights requests within thirty (30) days.

10. Children & Minors

If 23jl discovers or is notified that personal information has been collected from a person under 21 years of age, that information will be immediately deleted and the associated account will be permanently closed. If you are a parent or guardian and believe your child has registered on the 23jl Platform, please contact us immediately using the details in Section 13.

11. Cross-Border Data Transfers

Some of 23jl's service providers and game content partners operate from outside the Philippines. Where your personal information is transferred to a country outside the Philippines, 23jl ensures that adequate safeguards are in place to protect your information, including contractual data protection clauses that meet the standards required by the Data Privacy Act of 2012 and the National Privacy Commission.

23jl will not transfer your personal information to any jurisdiction that does not offer an adequate level of data protection without your prior consent or without implementing appropriate safeguards as required by Philippine law.

12. Amendments to This Policy

23jl 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 PAGCOR regulatory requirements. The "Last updated" date at the top of this document will be revised accordingly whenever material changes are made.

Where changes are significant, 23jl will notify registered players via their registered mobile number or email address prior to the changes taking effect. Your continued use of the 23jl Platform following notification constitutes your acceptance of the revised Privacy Policy.

13. Contact Our Data Privacy Team

For any questions, concerns, or requests relating to this Privacy Policy or your personal information held by 23jl, please contact our dedicated data privacy team:

You also have the right to file a complaint directly with the National Privacy Commission of the Philippines if you believe 23jl has violated your data privacy rights under the Data Privacy Act of 2012.