3jlmmm Privacy Policy — Your Data, Your Rights in the Philippines

3jlmmm is a Philippine-licensed online gaming platform operating at https://3jlmmm.net under a valid PAGCOR (Philippine Amusement and Gaming Corporation) license. In the context of this Privacy Policy, "3jlmmm", "we", "us", and "our" refer to the licensed operating entity responsible for the platform.

As a gaming operator serving Filipino players, 3jlmmm is a personal information controller under Republic Act No. 10173 — the Data Privacy Act of 2012 — and its Implementing Rules and Regulations. This means we are legally responsible for how personal data collected through the platform is processed, stored, and protected.

We have designated a Data Protection Officer (DPO) responsible for overseeing our data privacy compliance programme and serving as the primary point of contact for data privacy matters. You can reach our DPO and the 3jlmmm privacy team at privacy@3jlmmm.net. General enquiries and account support are handled at support@3jlmmm.net.

3jlmmm collects personal data from you in three main ways: information you provide directly when registering and using the platform, information generated automatically through your use of the platform, and information we may receive from third parties such as payment processors and identity verification services.

Information you provide directly:

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify you meet the 21+ age requirement)
• Philippine mobile number and email address
• Residential address in the Philippines
• Government-issued photo ID (PhilSys ID, Passport, Driver's License, SSS ID, or equivalent) — required for KYC verification before first withdrawal
• Payment method details (GCash number, Maya number, bank account details, card numbers) — stored in tokenised form, never as plain text
• Communications you send to the 3jlmmm support team
• Self-exclusion and responsible gaming preferences you set in your account

Information generated automatically:

• Device information (device type, operating system version, browser type)
• IP address and approximate location derived from IP
• Session timestamps, login history, and session duration
• Full betting and gaming transaction history on the 3jlmmm platform
• Deposit and withdrawal transaction records
• Pages visited within the 3jlmmm platform and features used
• Cookie and similar tracking data (see Section 7)

We do not collect sensitive personal information beyond what is necessary for identity verification and regulatory compliance. We do not store full payment card numbers — these are handled directly by our certified payment processors using tokenisation.

3jlmmm collects and processes your personal data only for specific, legitimate purposes. We do not collect data speculatively or in excess of what is necessary. The primary purposes are:

For marketing communications, 3jlmmm only contacts you if you have given explicit consent during registration or subsequently through your account communication preferences. You can withdraw marketing consent at any time from your account settings or by contacting support.

Under the Philippine Data Privacy Act (RA 10173), 3jlmmm must have a lawful basis for processing each category of personal data. We rely on the following legal bases:

• Contractual necessity: Processing required to provide the services you've signed up for — account management, payment processing, bet settlement, and customer support. Without this processing, we cannot provide you with the 3jlmmm service.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160), the Data Privacy Act itself, and other applicable Philippine laws. This includes KYC verification and regulatory transaction reporting.
• Legitimate interests: Processing that serves 3jlmmm's legitimate business interests, provided those interests do not override your rights. This covers fraud prevention, platform security, responsible gaming monitoring, and aggregated analytics for platform improvement.
• Your consent: Processing for marketing communications and certain cookie categories that are not strictly necessary. You can withdraw consent for these at any time.

3jlmmm does not sell, rent, or trade your personal information to any third party for commercial purposes. We share data only where necessary and only with parties that have agreed to process it in accordance with applicable Philippine data privacy requirements.

The categories of third parties with whom 3jlmmm may share your personal data are:

• Payment processors and e-wallet providers: GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, and card payment processors receive only the data necessary to process your specific transaction. Payment processors operate under their own privacy policies and regulatory obligations.
• Identity verification providers: Third-party KYC providers may process your identification documents and biometric data as part of the one-time identity verification process required before withdrawal. These providers are data processors acting under 3jlmmm's instructions.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and relevant Philippine law enforcement agencies may receive data as required by law or in response to lawful requests.
• Cloud and technology service providers: Hosting, database, security, and analytics services that process data on our behalf under data processing agreements that require them to maintain data privacy and security standards equivalent to 3jlmmm's own.
• Fraud prevention and security services: Providers that help 3jlmmm detect and prevent fraudulent activity, money laundering, and platform abuse.

When 3jlmmm engages third-party data processors, we conduct due diligence and enter into data processing agreements to ensure your data is handled appropriately. We do not transfer personal data outside the Philippines unless the receiving jurisdiction provides adequate data protection standards as assessed under RA 10173.

3jlmmm implements technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data in transit between your device and 3jlmmm servers.
• Encryption at rest for sensitive personal data stored in our databases, including identity document images and financial information.
• Tokenisation of payment method details — we never store full card numbers or bank account credentials in plain text.
• Access controls limiting data access to 3jlmmm staff on a strict need-to-know basis, with comprehensive audit logging of all data access events.
• Multi-factor authentication required for all administrative access to systems containing personal data.
• 24/7 security monitoring with automated intrusion detection and alerting systems.
• Regular security assessments including vulnerability testing and periodic review of our data processing practices.

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 3jlmmm will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay, as required under RA 10173.

3jlmmm uses cookies and similar tracking technologies to operate the platform and improve your experience. A cookie is a small text file placed on your device when you visit a website. We use the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function — session management, login authentication, security tokens, and shopping cart-equivalent functions (like maintaining your active bet slip). You cannot opt out of these without effectively being unable to use the platform.
• Functional cookies: Remember your preferences — language settings, display options, and regional settings. These make the 3jlmmm experience more personalised and convenient.
• Analytics cookies: Help us understand how players navigate the platform so we can identify issues and improve features. Data collected through analytics cookies is aggregated and anonymised where possible.
• Marketing cookies: Used to deliver relevant promotional communications and to measure the effectiveness of our marketing campaigns. These are only set with your explicit consent.

You can manage your cookie preferences at any time through your browser settings. Most browsers allow you to block or delete cookies. Note that disabling strictly necessary cookies will affect your ability to use the 3jlmmm platform. Marketing and analytics cookies can be opted out without impacting core platform functionality.

As a data subject under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by 3jlmmm. These rights apply within the limits permitted by RA 10173 and other applicable Philippine laws.

To exercise any of these rights, contact our Data Protection Officer at privacy@3jlmmm.net. We will verify your identity before processing any request and respond within 15 business days. Where a request involves a large amount of data or is complex, we may extend this period by a further 30 days with notification.

3jlmmm retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable Philippine law. Our data retention practices are:

• Active account data: Retained for the duration of your account and until you request closure, provided there are no regulatory holds on the account.
• Transaction and betting records: Retained for a minimum of 5 years after the transaction date, as required under PAGCOR licensing conditions and the Anti-Money Laundering Act.
• KYC and identity verification documents: Retained for a minimum of 5 years after account closure, in compliance with AMLC and PAGCOR record-keeping requirements.
• Customer support communications: Retained for 3 years from the date of the communication.
• Marketing consent records: Retained for the duration of your consent and for 1 year after withdrawal, as evidence of your consent decision.
• Aggregated analytics data: Retained indefinitely in anonymised form — this data cannot be used to identify individual players.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents re-identification. Where legal holds or ongoing investigations require extended retention, data will be held only for the minimum period necessary to fulfil that obligation.

3jlmmm is strictly an adults-only platform. We do not knowingly collect personal data from individuals under the age of 21. As required by PAGCOR regulations and Philippine gaming law, all players must be at least 21 years old to register and play.

If we discover that a person under 21 has provided personal data to 3jlmmm — whether through misrepresentation during registration or any other means — we will immediately suspend the account, delete the associated personal data, and void any transactions made through the account. Any funds deposited by a minor will be returned to the source payment method after standard compliance checks.

Parents and guardians who believe a minor has accessed the 3jlmmm platform should contact our support team immediately at support@3jlmmm.net. We also encourage parents and guardians to use parental control software to prevent minors from accessing online gaming platforms.

The 3jlmmm platform may contain references to third-party services such as payment providers and regulatory bodies. 3jlmmm is not responsible for the data practices of any third-party website or service. When you leave the 3jlmmm platform to visit or use a third-party service — even one we recommend or have integrated with — that third party's own privacy policy governs how your data is handled.

We recommend reviewing the privacy policies of any third-party services you use in connection with your 3jlmmm account, particularly your chosen payment provider (GCash, Maya, etc.). Payment providers operate under their own terms, privacy policies, and financial regulatory obligations which are independent of 3jlmmm.

3jlmmm reviews and updates this Privacy Policy periodically to reflect changes in our practices, applicable Philippine law, regulatory requirements, or our services. Material changes — those that significantly affect your rights or how your personal data is used — will be communicated to registered players via email or through a prominent in-platform notification.

The "Last Updated" date displayed at the top of this page indicates when the most recent changes were made. We encourage you to review this policy periodically. Continued use of the 3jlmmm platform after a notified update constitutes acceptance of the revised policy. If you do not agree with changes to this policy, you should stop using the platform and contact us regarding your account.

For any questions, concerns, or requests related to this Privacy Policy or the handling of your personal data at 3jlmmm, please contact us through the following channels:

• Data Protection Officer: privacy@3jlmmm.net — for data access requests, erasure requests, complaints, and privacy-related enquiries.
• General Support: support@3jlmmm.net — for account issues and general platform enquiries.
• Live Chat: Available within your logged-in 3jlmmm account for real-time assistance.

If you are not satisfied with how 3jlmmm has handled a data privacy concern, you have the right to escalate to the National Privacy Commission (NPC) of the Philippines — the government body responsible for overseeing enforcement of RA 10173. The NPC accepts complaints through its official website and offers a mediation process for data privacy disputes.