e3jl Privacy Policy

Introduction

e3jl operates an online gaming platform accessible at https://e3jl.app, offering live casino games, slots, bingo, and fishing games to players in the Philippines. In the course of providing these services, e3jl necessarily collects and processes certain personal data about its users.

This Privacy Policy applies to all personal data collected by e3jl through the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and use of our website. It applies to all registered Players and to visitors who browse the Platform without registering.

This Policy should be read alongside our Terms & Conditions, which govern your use of the e3jl Platform. By accessing or using e3jl, you acknowledge that you have read and understood this Privacy Policy.

Data Controller

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, e3jl is the personal information controller in respect of the personal data collected through the Platform. This means e3jl determines the purposes and means of processing your personal data.

e3jl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data privacy laws and for handling data subject requests. Contact details for the DPO are provided in Section 15 of this Policy.

Data We Collect

e3jl collects the following categories of personal data, depending on how you interact with the Platform:

Identity Data:

• Full legal name
• Date of birth (for age verification — you must be 21 or older)
• Government-issued identification number (when required for verification)
• Photograph or selfie (when required for identity verification)

Contact Data:

• Email address
• Mobile phone number
• Residential address (city, province, region)

Financial Data:

• GCash or PayMaya account details (mobile number associated with the account)
• Bank account details for BPI, BDO, or Metrobank transfers (account name and number)
• Transaction history (deposits, withdrawals, wager amounts)
• Source-of-funds documentation (when required by anti-money laundering regulations)

Technical Data:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration and login timestamps
• Cookies and similar tracking technologies (see Section 8)

Gaming Data:

• Game history, wager amounts, wins, and losses
• Bonus and promotion usage
• Responsible gaming settings and self-exclusion records

Communications Data:

• Records of customer support interactions via chat or email
• Feedback and survey responses
• Marketing communication preferences

How We Collect Data

e3jl collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or responding to surveys and promotions.
• Automated collection: Data collected automatically when you access the Platform, including technical data gathered through cookies, web beacons, and server logs.
• Third-party sources: Data received from identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud prevention services, and regulatory authorities where permitted by law.

How We Use Your Data

e3jl uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your e3jl account, including verifying your identity and age (21+ requirement).
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the features of the Platform.
• Legal compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering obligations, age verification requirements, and reporting obligations to regulatory authorities.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: To monitor gaming behavior, enforce responsible gaming limits, and respond to self-exclusion requests.
• Customer support: To respond to your inquiries, resolve disputes, and improve our support services.
• Marketing communications: To send you promotional offers, bonuses, and news about e3jl — subject to your marketing preferences and applicable law.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features and performance of the Platform.
• Financial processing: To process transactions via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.

Legal Basis for Processing

e3jl processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — i.e., to provide the e3jl Platform and its services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, age verification requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for e3jl's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Data Sharing

e3jl does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC (Know Your Customer) and age verification services used to verify your identity and comply with regulatory requirements.
• Game providers: Third-party game software providers whose games are available on the Platform may receive limited technical data necessary for game operation.
• Regulatory authorities: Philippine government agencies and regulatory bodies, including the National Privacy Commission, where disclosure is required by law.
• Fraud prevention services: Third-party providers that assist e3jl in detecting and preventing fraudulent activity on the Platform.
• Professional advisers: Lawyers, auditors, and other professional advisers where necessary for legal, compliance, or business purposes.

All third parties with whom e3jl shares personal data are required to handle that data in accordance with applicable privacy laws and e3jl's data processing requirements. e3jl does not authorize third parties to use your personal data for their own marketing purposes.

Cookies & Tracking Technologies

e3jl uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. They help us recognize your browser, remember your preferences, and analyze how the Platform is used.

e3jl uses the following types of cookies:

• Essential cookies: Required for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and responsible gaming limits, to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how Players use the Platform, helping us identify areas for improvement. This data does not identify you personally.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

Data Retention

e3jl retains personal data for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, and reporting obligations. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Identity verification documents: Retained for the period required by applicable KYC and AML regulations.
• Customer support records: Retained for three (3) years from the date of the interaction.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.

When personal data is no longer required, e3jl will securely delete or anonymize it in accordance with our data disposal procedures.

Data Security

e3jl implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing of the Platform.
• Two-factor authentication options for Player accounts.
• Incident response procedures for detecting, reporting, and responding to data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, e3jl will notify the National Privacy Commission and affected data subjects in accordance with the requirements of RA 10173 and NPC regulations.

Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by e3jl:

• Right to be informed: The right to be informed about how your personal data is collected and processed — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data e3jl holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to legal retention requirements.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact e3jl's Data Protection Officer using the details in Section 15. e3jl will respond to all data subject requests within the timeframe required by applicable law.

Children's Privacy

The e3jl Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gambling regulations. e3jl does not knowingly collect personal data from individuals under the age of 21.

If e3jl becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and take appropriate action in accordance with applicable law.

If you are a parent or guardian and believe that your child has provided personal data to e3jl, please contact us immediately using the details in Section 15 so that we can take appropriate action.

International Data Transfers

e3jl primarily processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international game software companies.

Where personal data is transferred outside the Philippines, e3jl ensures that appropriate safeguards are in place to protect your data, including contractual data processing agreements that require recipients to maintain standards equivalent to those required under RA 10173.

e3jl will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining your consent.

Policy Updates

e3jl reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. The effective date at the top of this document indicates when the Policy was last revised.

Where changes are material, e3jl will notify registered Players via the email address associated with their account prior to the changes taking effect. For non-material changes, the updated Policy will be published on the Platform and will take effect immediately upon publication.

We encourage you to review this Privacy Policy periodically to stay informed about how e3jl protects your personal data. Your continued use of the Platform following any update constitutes your acceptance of the revised Policy.

Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by e3jl, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Response Time: e3jl aims to acknowledge all privacy-related requests within 72 hours and to resolve them within the timeframe required by RA 10173.

If you are not satisfied with e3jl's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.