16jl Privacy Policy — Your Data, Protected

1. Introduction

16jl is committed to protecting the privacy and personal data of all players and visitors to the 16jl platform. We understand that trust is the foundation of any relationship between a player and an online gaming platform, and we take our data protection responsibilities seriously.

This Privacy Policy describes the types of personal information we collect, the purposes for which we use it, the circumstances under which we may share it with third parties, and the rights you have in relation to your personal data. It is designed to be transparent, straightforward, and compliant with the requirements of Republic Act No. 10173 (the Data Privacy Act of 2012) and the regulations of the National Privacy Commission of the Philippines.

By registering an account on 16jl or otherwise using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2. Personal Data We Collect

16jl collects personal data in the following categories:

Registration and Identity Data

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Gender
• Nationality and country of residence
• Email address
• Mobile phone number
• Residential address
• Government-issued identification documents (e.g., Philippine passport, driver's license, SSS/GSIS ID, PhilSys ID) — collected for identity verification and KYC compliance

Financial Data

• GCash or Maya account details (mobile number linked to e-wallet)
• Bank account details for bank transfer transactions
• Debit card details (card number, expiry, cardholder name — processed securely and not stored in full)
• Transaction history, including deposits, withdrawals, and bonus activity

Gaming Activity Data

• Game play history, including games played, bets placed, wins, and losses
• Session duration and frequency of play
• Bonus and promotion usage
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status)

Technical and Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Pages visited, links clicked, and time spent on the platform

Communications Data

• Records of communications with 16jl customer support, including live chat transcripts and email correspondence
• Feedback, complaints, and dispute records

3. How We Use Your Personal Data

16jl uses the personal data we collect for the following purposes:

• Account creation and management: To register your account, verify your identity, and manage your player profile on the 16jl platform.
• Age and identity verification: To confirm that you are at least 21 years of age and to comply with Know Your Customer (KYC) requirements under PAGCOR regulations and anti-money laundering law.
• Payment processing: To facilitate deposits and withdrawals using GCash, Maya, debit cards, and Philippine bank transfers, and to maintain accurate transaction records.
• Game delivery and platform operation: To provide access to all games and features on the 16jl platform, to record game results, and to calculate and credit winnings.
• Bonuses and promotions: To determine your eligibility for promotions, to credit bonus funds, and to monitor compliance with bonus terms and conditions.
• Customer support: To respond to your inquiries, resolve disputes, and provide assistance through live chat and email.
• Responsible gaming: To monitor gaming activity for signs of problem gambling, to enforce responsible gaming tools you have activated, and to comply with PAGCOR's responsible gaming requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the platform.
• Legal and regulatory compliance: To meet our obligations under Philippine law, PAGCOR regulations, and the Data Privacy Act of 2012, including record-keeping and reporting requirements.
• Platform improvement: To analyze usage patterns, identify technical issues, and improve the features and performance of the 16jl platform.
• Marketing communications: To send you promotional offers, newsletters, and updates about 16jl — only where you have given your consent to receive such communications. You may withdraw this consent at any time.

4. Legal Basis for Processing

16jl processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between you and 16jl — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, anti-money laundering obligations, and tax reporting requirements.
• Legitimate interests: Processing is necessary for 16jl's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and certain non-essential cookies, processing is based on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5. Sharing Your Personal Data

16jl does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly for the purposes described in this Privacy Policy:

• Payment service providers: GCash, Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and identity verification services used to confirm your identity and age in compliance with regulatory requirements.
• Game software providers: Licensed game developers and providers whose games are available on the 16jl platform, to the extent necessary to deliver game services.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulation.
• Fraud prevention and security services: Third-party providers that assist 16jl in detecting and preventing fraud, money laundering, and other illegal activity.
• IT and infrastructure providers: Cloud hosting, data storage, and technical support providers who process data on 16jl's behalf under strict data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants, where necessary for the conduct of 16jl's business.

All third parties with whom 16jl shares personal data are required to handle that data in accordance with applicable data protection law and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

6. Cookies and Tracking Technologies

16jl uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage, and deliver relevant content. The types of cookies we use include:

• Strictly necessary cookies: Essential 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 display options, to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how visitors 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 your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 16jl platform. For strictly necessary cookies, no opt-out is available as they are required for the platform to operate.

7. Data Retention

16jl retains personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and anti-money laundering record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• Gaming activity data: Retained for a minimum of three (3) years from the date of the activity.
• Customer support communications: Retained for three (3) years from the date of the communication, or longer if related to an ongoing dispute or regulatory matter.
• Marketing consent records: Retained for as long as you remain subscribed to marketing communications, plus one (1) year following unsubscription.

When personal data is no longer required, 16jl will securely delete or anonymize it in accordance with our data disposal procedures.

8. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and NPC regulations, you have the following rights in relation to your personal data held by 16jl:

• Right to be informed: The right to know that your personal data is being collected and processed, and to receive clear information about how it is used — which this Privacy Policy provides.
• Right of access: The right to request a copy of the personal data 16jl holds about you.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to request deletion of your personal data, subject to our legal and regulatory retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller, where technically feasible.
• Right to lodge a complaint: The right to file 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 16jl's Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days, in accordance with NPC guidelines.

9. Data Security

16jl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 16jl platform
• AES-256 encryption for sensitive data stored in our databases
• Two-factor authentication (2FA) available for all player accounts
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis
• Regular security audits and penetration testing by independent security professionals
• Intrusion detection and monitoring systems operating 24 hours a day, 7 days a week
• Secure data disposal procedures for data that is no longer required

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 16jl will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with NPC Circular No. 16-03.

10. Children and Minors

The 16jl platform is strictly intended for adults aged 21 years and above. 16jl does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately suspend the associated account, delete the data, and take appropriate action in accordance with our Terms & Conditions and applicable law.

If you are a parent or guardian and believe that a minor has registered on the 16jl platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

11. Changes to This Privacy Policy

16jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The effective date at the top of this page will be updated whenever a material change is made.

Where changes are significant, 16jl will notify registered players by email or through an in-platform notification. Your continued use of the 16jl platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised policy, you should cease using the platform and may request account closure.

12. Contact Us and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 16jl handles your personal data, please contact our Data Protection Officer:

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through the 16jl platform

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) through its official channels.