635jl Privacy Policy — Your Data, Your Rights

1. Introduction

This Privacy Policy ("Policy") describes how 635jl ("the Platform", "we", "us", "our") collects, uses, stores, shares, and protects the personal information of users ("Members", "you", "your") who access or use the 635jl online gaming platform at https://635jl.best.

635jl respects the privacy of every Filipino member and is committed to handling personal data responsibly and transparently. This Policy is written in plain, straightforward English so that every 635jl member — wherever they are in the Philippines — understands how their information is managed.

By registering for a 635jl account or using any part of our platform, you acknowledge that you have read and understood this Privacy Policy, and you consent to the collection and processing of your personal data as described herein. If you disagree with any part of this Policy, please do not create a 635jl account.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules, 635jl is the Personal Information Controller in respect of all personal data collected from its members through the 635jl platform.

635jl has designated a Data Protection Officer (DPO) who is responsible for overseeing data protection matters and ensuring compliance with Philippine data privacy regulations. You can contact the DPO at any time via email at support@635jl.best, clearly marking your message as a "Data Privacy Concern" in the subject line.

635jl complies with the guidelines and directives of the National Privacy Commission (NPC) of the Philippines, which is the regulatory authority responsible for overseeing data privacy compliance in the country.

3. Personal Data We Collect

635jl collects the minimum personal data necessary to operate your account, verify your identity, process payments, and comply with applicable laws. The categories of personal information we collect include:

635jl does not collect sensitive personal information such as racial or ethnic origin, religious beliefs, health records, or biometric data, except where a government-issued ID document incidentally contains such information as part of standard KYC verification.

4. How We Collect Your Data

635jl collects personal data through the following means:

• Direct submission: Information you enter when registering for a 635jl account, completing KYC verification, submitting withdrawal requests, or contacting customer support.
• Automated collection: Technical and usage data collected automatically when you access the 635jl platform, through server logs, session tracking, and cookies (see Section 10).
• Third-party sources: Identity verification data confirmed through licensed KYC service providers; payment verification data provided by GCash, Maya, and other payment processors in connection with deposit and withdrawal transactions.
• Referral programme: If you were referred to 635jl by an existing member through the Refer a Friend programme, we may receive your contact information from the referring member. In this case, we will notify you of this upon first contact from 635jl.

5. Why We Use Your Personal Data

635jl uses your personal data for the following specific purposes:

• Account management: To create, maintain, and secure your 635jl account, including OTP authentication and password recovery.
• Identity verification (KYC): To verify that you are who you say you are, that you meet the minimum age requirement (21+), and that your account is not being used for fraudulent purposes.
• Payment processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and other accepted payment methods. Your financial data is shared only with the relevant payment processor for the specific transaction.
• Regulatory compliance: To fulfil 635jl's obligations under Philippine gaming regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act. This includes transaction reporting where legally required.
• Customer support: To respond to your queries, complaints, and support requests via live chat and email.
• Platform improvement: To analyse usage patterns and technical performance data to improve the 635jl platform experience for all Filipino members.
• Fraud prevention: To detect and investigate suspicious activity, bonus abuse, duplicate accounts, and other conduct prohibited under the 635jl Terms and Conditions.
• Responsible gaming: To monitor patterns that may indicate problem gambling behaviour, and to facilitate your use of responsible gaming tools such as deposit limits and self-exclusion.
• Communications: To send you service-related notifications about your account, transactions, and important policy updates. With your separate consent, we may also send promotional communications about 635jl offers and new game launches.

6. Legal Basis for Processing

635jl processes your personal data under the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Consent: For account registration, promotional communications, and cookie-based tracking where consent is required. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contractual necessity: Processing required to fulfil the agreement between you and 635jl — including operating your account, processing bets, and handling deposits and withdrawals.
• Legal obligation: Processing required to comply with Philippine law, including AMLA reporting obligations, gaming regulatory requirements, and NPC directives.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring — provided these interests are not overridden by your data privacy rights.

7. How We Share Your Data

635jl does not sell your personal data to any third party for commercial marketing purposes. Your information is shared only in the following limited, necessary circumstances:

• Payment processors: GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, and card processors — only the data required to complete your transaction is shared.
• Game providers: JILI and other certified game providers receive anonymised session identifiers to operate game mechanics. They do not receive your identity or financial data.
• KYC providers: Licensed identity verification service providers who process your ID documents to confirm your identity on behalf of 635jl, under strict data processing agreements.
• Regulatory bodies: Philippine gaming regulators, the AMLC (Anti-Money Laundering Council), and the NPC — when disclosure is required by law or court order.
• Technology partners: Cloud hosting and security infrastructure providers who process data solely on 635jl's instruction under contractual data processing agreements that prohibit independent use of your data.

8. Data Retention Periods

635jl retains your personal data for as long as is necessary for the purposes described in this Policy, and in accordance with applicable Philippine legal requirements. Specific retention guidelines are as follows:

• Active account data: Retained for the full duration of your membership with 635jl and for a period of at least five (5) years following account closure, as required by Philippine AMLA regulations.
• KYC and identity documents: Retained for a minimum of five (5) years from the date of verification, consistent with AMLA and gaming regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support communications: Live chat and email correspondence retained for up to three (3) years for quality assurance, dispute resolution, and compliance purposes.
• Technical and usage data: Anonymised log data retained for up to twelve (12) months for platform performance and security monitoring.

When personal data is no longer required and no legal retention obligation applies, 635jl will securely delete or anonymise the data using processes that prevent recovery or reconstruction.

9. Data Security

635jl implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the 635jl platform.
• Encryption at rest for stored personal data, including identity documents and financial records.
• Two-factor authentication (OTP) for account login and sensitive account actions.
• Role-based access controls that restrict internal access to personal data to authorised staff with a legitimate need.
• Regular security assessments and penetration testing by qualified security professionals.
• Automated fraud detection and account monitoring systems that flag unusual activity for investigation.

Despite these measures, no online platform can guarantee absolute security. If you suspect your 635jl account has been compromised, please change your password immediately and contact our support team via live chat or at support@635jl.best.

10. Cookies and Tracking Technologies

635jl uses cookies and similar tracking technologies on the platform to improve your experience, maintain your login session, and gather platform usage analytics. The types of cookies used by 635jl are:

• Strictly necessary cookies: Required for the platform to function — login session management, security tokens, and preferences storage. These cannot be disabled without breaking core functionality.
• Analytics cookies: Used to understand how members use the 635jl platform — which pages are visited most, where users drop off, and how performance can be improved. Data collected is aggregated and anonymised.
• Functional cookies: Remember your language preference, device settings, and other personalisation choices to make your 635jl experience more consistent.

635jl does not use third-party advertising cookies or share cookie data with advertisers. You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies may affect the functionality of your 635jl account.

11. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, every 635jl member has the following data privacy rights. You may exercise any of these rights by contacting our Data Protection Officer at support@635jl.best.

635jl will respond to data rights requests within thirty (30) calendar days of receipt. In cases requiring additional time due to complexity, we will notify you of the expected extended timeframe within the initial thirty-day window.

12. Protection of Minors

635jl's platform is strictly for individuals who are 21 years of age or older, consistent with Philippine gaming law. 635jl does not knowingly collect personal data from individuals under 21 years of age.

If 635jl discovers that a person under 21 has provided personal data during account registration, the account will be immediately closed, all data will be deleted, and any deposited funds will be returned to the payment source after identity verification. Parents or guardians who believe a minor has created a 635jl account should contact support@635jl.best immediately for prompt resolution.

13. Cross-Border Data Transfers

635jl primarily stores and processes member data within the Philippines. In limited circumstances, some data may be processed by technology or KYC service partners whose servers are located outside the Philippines — for example, cloud infrastructure providers.

Where personal data is transferred outside the Philippines, 635jl ensures that appropriate safeguards are in place to provide a level of data protection equivalent to that required under the Philippine Data Privacy Act. These safeguards include contractual data processing agreements that bind third-party processors to confidentiality and data protection obligations consistent with Philippine standards.

635jl will not transfer your personal data to jurisdictions that do not provide adequate data protection standards without first obtaining your explicit consent or implementing appropriate contractual protections.

14. Changes to This Privacy Policy

635jl may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. When material changes are made, 635jl will notify registered members via email or in-platform notification at least seven (7) days before the updated Policy takes effect.

The date of the most recent update is displayed at the top of this page. We encourage all 635jl members to review this Policy periodically to stay informed about how their personal data is being protected. Continued use of the 635jl platform after the effective date of a revised Policy constitutes your acceptance of the changes.

If you disagree with any updated Privacy Policy, you have the right to request account closure by contacting our support team. Any personal data subject to mandatory legal retention will be retained for the required period even after account closure, as described in Section 8.

15. Contact Our Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data privacy rights, or need to raise a data protection concern, please contact 635jl's Data Protection Officer through any of the following channels:

• Email: support@635jl.best — please use the subject line "Data Privacy Request" for priority routing.
• Live Chat: Available 24/7 through the chat icon in your logged-in 635jl account. Inform the agent that your query is a "data privacy matter" and it will be escalated to the DPO team.
• FAQ: Visit our FAQ page for quick answers to common questions about your 635jl account and data rights.

For complaints about 635jl's handling of your personal data that remain unresolved after our internal process, you have the right to escalate to the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority for data privacy matters in the Philippines.