Privacy Policy – 28jl16 Data Protection

1 Introduction

1.1 28jl16 is committed to protecting the privacy and personal data of all players and users of the 28jl16 platform. We recognise that trust is the foundation of any good relationship — and that means being transparent about how we handle your information.

1.2 This Policy applies to all personal data collected through the 28jl16 website, mobile interface, customer support channels, and any other touchpoint through which you interact with 28jl16.

1.3 28jl16 processes personal data in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission ("NPC"). Where applicable, we also comply with PAGCOR's data handling requirements for licensed online gaming operators.

1.4 If you have any questions about this Policy or how 28jl16 handles your personal data, please contact our Data Protection Officer at the details provided in Section 14.

2 Personal Data We Collect

2.1 28jl16 collects the following categories of personal data:

• Identity Data: Full legal name, date of birth, nationality, government-issued ID number (e.g., Philippine National ID, passport, driver's licence, SSS/GSIS number).
• Contact Data: Email address, mobile number, residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, Makati).
• Account Data: Username, encrypted password, account registration date, account status, and login history.
• Financial Data: GCash account number, PayMaya / Maya account details, bank account details (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), debit card details (last four digits only), deposit and withdrawal history, and account balance records.
• Gaming Data: Game history, wager amounts, win/loss records, session duration, and responsible gaming tool usage (deposit limits, self-exclusion status).
• Technical Data: IP address, device type, operating system, browser type and version, time zone, and platform access logs.
• Communications Data: Records of your interactions with 28jl16 customer support, including live chat transcripts and email correspondence.
• KYC Documentation: Copies of government-issued identification documents and proof of address submitted during the KYC verification process.

2.2 28jl16 does not collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for KYC compliance and regulatory reporting. We do not collect biometric data, health information, or political affiliations.

3 How We Collect Your Data

3.1 28jl16 collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the 28jl16 platform, including IP address, device identifiers, and browsing behaviour within the platform, via cookies and server logs.
• Third-Party Sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment confirmation data from GCash, PayMaya, and banking partners.

3.2 28jl16 does not purchase personal data from data brokers or third-party marketing lists.

4 How We Use Your Personal Data

4.1 28jl16 uses your personal data for the following purposes:

• To create, verify, and manage your 28jl16 account.
• To process deposits and withdrawals through GCash, PayMaya, and Philippine bank partners.
• To conduct KYC verification and ongoing due diligence as required by PAGCOR and Philippine AML regulations.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities.
• To provide customer support and respond to your enquiries.
• To administer bonuses, promotions, and loyalty programmes.
• To enforce the 28jl16 Terms & Conditions and Responsible Gaming Policy.
• To send you transactional communications (e.g., deposit confirmations, withdrawal notifications, account security alerts).
• To send you promotional communications about 28jl16 offers and events, where you have consented to receive such communications.
• To analyse platform usage and improve the 28jl16 user experience.
• To comply with applicable laws, regulations, and regulatory reporting obligations.

4.2 28jl16 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or with your explicit consent.

5 Legal Basis for Processing

5.1 28jl16 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform our obligations under the 28jl16 Terms & Conditions, including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with PAGCOR regulations, AML obligations, KYC requirements, and other applicable Philippine laws.
• Legitimate Interests: Processing for fraud prevention, platform security, and improving the 28jl16 service, where such interests are not overridden by your data privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing and Disclosure

6.1 28jl16 does not sell, rent, or trade your personal data to third parties for commercial purposes.

6.2 28jl16 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Processors: GCash, PayMaya / Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals.
• KYC and Compliance Providers: Identity verification and AML screening service providers engaged to assist with regulatory compliance.
• Game Providers: Third-party game software providers whose games are integrated into the 28jl16 platform, to the extent necessary for game operation and fairness auditing.
• IT and Security Providers: Cloud hosting, cybersecurity, and fraud detection service providers who process data on our behalf under strict data processing agreements.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where disclosure is required by law or regulatory order.
• Legal and Professional Advisers: Lawyers, auditors, and other professional advisers, subject to professional confidentiality obligations.

6.3 In the event of a merger, acquisition, or sale of all or part of 28jl16's business, your personal data may be transferred to the acquiring entity, subject to the same data protection standards described in this Policy.

7 Cookies and Tracking Technologies

7.1 28jl16 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 28jl16 website.

7.2 28jl16 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations. These improve your experience but are not strictly required.
• Analytics Cookies: Collect anonymised data about how players use the 28jl16 platform — which pages are visited most, where users drop off, and how features are used. This data helps us improve the platform. No personally identifiable information is included in analytics data.

7.3 28jl16 does not use third-party advertising or retargeting cookies. We do not allow third-party ad networks to place cookies on the 28jl16 platform.

7.4 You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling certain cookies may affect the functionality of the 28jl16 platform.

8 Data Retention

8.1 28jl16 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation.

8.2 The following retention periods apply as a general guide:

• 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 AMLC record-keeping requirements.
• Financial and Transaction Data: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations.
• KYC Documentation: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Gaming History: Retained for a minimum of three (3) years for dispute resolution and regulatory audit purposes.
• Customer Support Records: Retained for two (2) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Technical and Log Data: Retained for twelve (12) months for security monitoring and fraud detection purposes.

8.3 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with 28jl16's data disposal procedures.

9 Data Security

9.1 28jl16 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 28jl16 platform.
• AES-256 encryption for sensitive data stored in our databases, including financial data and KYC documentation.
• Strict access controls ensuring that personal data is accessible only to authorised 28jl16 personnel and service providers on a need-to-know basis.
• Multi-factor authentication requirements for internal systems that process personal data.
• Regular security audits, vulnerability assessments, and penetration testing conducted by independent security specialists.
• Intrusion detection and prevention systems monitoring the 28jl16 platform in real time.
• Staff training on data privacy and security obligations under the Data Privacy Act of 2012.

9.2 In the event of a personal data breach that is likely to result in harm to affected individuals, 28jl16 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the DPA and NPC guidelines.

9.3 While 28jl16 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials and for notifying 28jl16 immediately if you suspect any unauthorised access to your account.

10 Your Data Privacy Rights

10.1 Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 28jl16:

10.2 To exercise any of the above rights, please contact the 28jl16 Data Protection Officer at the details provided in Section 14. We will respond to all verified requests within thirty (30) days of receipt, in accordance with NPC guidelines.

10.3 28jl16 may need to verify your identity before processing a data rights request to ensure that personal data is not disclosed to unauthorised parties.

11 Children's Privacy and Age Restriction

11.1 The 28jl16 platform is strictly intended for adults aged 21 years and above, in compliance with PAGCOR regulations applicable in the Philippines. 28jl16 does not knowingly collect personal data from individuals under the age of 21.

11.2 If 28jl16 becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account.

11.3 If you are a parent or guardian and believe that a minor has registered an account on the 28jl16 platform, please contact us immediately at [email protected] so that we can take appropriate action.

12 International Data Transfers

12.1 28jl16 primarily processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines — for example, cloud infrastructure providers or game software vendors — 28jl16 ensures that such transfers are subject to appropriate safeguards.

12.2 Safeguards for international data transfers include contractual clauses that impose data protection obligations on the recipient equivalent to those required under the Data Privacy Act of 2012, and where applicable, transfers only to jurisdictions recognised by the NPC as providing an adequate level of data protection.

12.3 28jl16 does not transfer personal data to jurisdictions that do not provide adequate data protection safeguards without your explicit consent or a lawful basis under the DPA.

13 Updates to This Privacy Policy

13.1 28jl16 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent update is displayed at the top of this page.

13.2 Where changes to this Policy are material, 28jl16 will notify registered players via email or a prominent notice on the platform prior to the changes taking effect. We encourage you to review this Policy periodically to stay informed about how 28jl16 protects your personal data.

13.3 Your continued use of the 28jl16 platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the revised Policy.

14 Contact Us and Data Protection Officer

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 28jl16, please contact our Data Protection Officer:

14.2 28jl16 will acknowledge all data privacy enquiries within three (3) business days and will endeavour to resolve all requests within thirty (30) days of receipt.