23jl Privacy Policy

The data controller responsible for the processing of personal information collected through 23jl.club is the operator of the 23jl platform, a PAGCOR-licensed entity operating under the laws of the Republic of the Philippines.

For all data privacy inquiries, requests, and complaints, you may contact our designated Data Protection Officer (DPO) using the contact details provided in Section 13 of this Policy. 23jl is registered with the National Privacy Commission (NPC) of the Philippines as required under the Data Privacy Act of 2012 and its Implementing Rules and Regulations (IRR).

23jl collects the following categories of personal data from users and visitors to 23jl.club:

• Full legal name as it appears on a government-issued ID
• Date of birth (required for age verification — players must be 21 years or older)
• Nationality and country of residence
• Username and encrypted password
• Mobile number and email address

• Government-issued identification documents (e.g., Philippine passport, driver's license, UMID, PhilSys National ID)
• Proof of address documents (e.g., utility bills, barangay certificates)
• Selfie photographs submitted for identity verification

• GCash or Maya (PayMaya) mobile wallet identifiers (masked)
• Bank account details for BPI, BDO, Metrobank, and other Philippine banks (masked)
• Deposit and withdrawal transaction history
• Bonus credits, wagering activity, and gaming session financial records

• Game history, bet amounts, win/loss records, and session durations
• Sports betting activity including selected events and wager amounts
• Responsible gaming tool usage (deposit limits set, self-exclusion requests)
• Customer support interaction history

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps, page view logs, and navigation patterns
• Cookie identifiers and similar tracking technology data (see Section 7)

23jl collects personal data through the following means:

• Direct submission: Information you provide during the 23jl registration process, KYC verification, deposit and withdrawal requests, customer support interactions, and responsible gaming tool configuration.
• Automated collection: Technical data collected automatically when you access 23jl.club, including through cookies, server logs, and analytics tools (see Section 7).
• Third-party providers: Identity verification data from KYC service providers; transaction data from payment processors including GCash, Maya, and banking partners; geolocation data from IP intelligence services.
• PAGCOR regulatory reporting: In compliance with PAGCOR requirements, certain gaming activity data is reportable to and may be provided by PAGCOR or its authorized agents.

23jl processes your personal data for the following specific, legitimate purposes:

• Account creation and management: To register, maintain, and administer your 23jl Account.
• Identity and age verification: To verify that you are at least 21 years of age and to satisfy PAGCOR KYC requirements before enabling deposit and withdrawal functions.
• Payment processing: To process your GCash, Maya, and bank deposits and withdrawals accurately and securely.
• Game provision: To deliver casino games, live dealer tables, slots, bingo, and sports betting services to you, and to maintain accurate game records.
• Regulatory compliance: To comply with PAGCOR licensing obligations, the Anti-Money Laundering Act (AMLA), and reporting requirements to Philippine regulatory authorities.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, underage gambling, and unauthorized account access.
• Responsible gaming: To monitor gaming behavior, implement player-requested limits, and proactively identify indicators of problem gambling in accordance with PAGCOR responsible gaming standards.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing communications: To send promotional offers, bonus notifications, and updates about new 23jl features — subject to your consent and opt-out preferences.
• Platform improvement: To analyze aggregate usage data to improve the 23jl platform's performance, user experience, and game catalog.

Under the Philippine Data Privacy Act of 2012, 23jl processes personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between 23jl and registered users — including account management, game provision, and payment processing.
• Legal obligation: Processing required for 23jl to comply with its obligations under PAGCOR regulations, AMLA, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed, and freely given consent and may withdraw it at any time.

23jl does not sell, rent, or trade your personal data to third parties for commercial purposes. We share data only in the following limited circumstances:

• Payment processors: GCash (G-Xchange Inc.), PayMaya Philippines Inc., and Philippine banking partners receive only the data necessary to process your transactions.
• KYC and identity verification providers: Third-party verification services receive identification documents solely for the purpose of completing required identity checks.
• PAGCOR and regulatory authorities: 23jl is legally required to report certain gaming activity, suspicious transactions, and player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities.
• IT and hosting providers: Cloud infrastructure and software vendors who process data solely on 23jl's instructions under data processing agreements compliant with the Data Privacy Act.
• Legal proceedings: Where disclosure is required by a valid court order, subpoena, or legal process issued by a Philippine court or competent authority.

23jl.club uses cookies and similar technologies to operate the platform and improve your experience. The categories of cookies used are:

• Strictly necessary cookies: Required for the Platform to function — session management, login state, security tokens. These cannot be disabled without affecting core functionality.
• Functional cookies: Remember your preferences such as language settings, game display options, and responsible gaming limits you have configured.
• Analytics cookies: Aggregate, anonymized data about how visitors use 23jl.club, used to identify performance issues and improve the platform. Used only with your consent.
• Marketing cookies: Used to show relevant 23jl promotions based on your activity. Only placed with your explicit consent and can be withdrawn at any time.

You may manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of specific 23jl features. 23jl does not use cookies to sell data to third-party advertisers.

23jl retains personal data only for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required by Philippine law or PAGCOR regulations.

• Active account data: Retained for the duration of your active 23jl Account plus five (5) years following account closure, in compliance with PAGCOR record-keeping requirements.
• Transaction and gaming records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC documents: Retained for five (5) years post-account closure or longer if required by ongoing regulatory proceedings.
• Marketing consent records: Retained until you withdraw consent, plus a period sufficient to demonstrate compliance with consent obligations.
• Technical logs: Retained for up to twelve (12) months for security monitoring and debugging purposes, then securely deleted.

23jl implements technical and organizational security measures appropriate to the nature and volume of personal data we process. These measures include:

• TLS encryption for all data in transit between your device and 23jl servers
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records
• Multi-factor authentication options for 23jl Account access
• Role-based access controls limiting internal staff access to personal data on a need-to-know basis
• Regular penetration testing and security audits by qualified third-party security professionals
• Incident response procedures aligned with NPC breach notification requirements under the Data Privacy Act

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by 23jl:

To exercise any of these rights, contact our Data Protection Officer as described in Section 13. 23jl will respond to all valid data subject requests within thirty (30) calendar days of receipt, in accordance with NPC guidelines.

The 23jl Platform is strictly for persons aged 21 years old and above, in compliance with PAGCOR regulations governing online gaming in the Philippines. 23jl does not knowingly collect personal data from individuals under the age of 21.

If 23jl discovers that personal data has been collected from a person under 21 — whether through circumvention of age verification controls or otherwise — that Account will be immediately suspended, all associated data will be reviewed and deleted in accordance with applicable law, and the matter reported to PAGCOR.

Parents and guardians who believe their child under 21 may have registered at 23jl are urged to contact our Data Protection Officer immediately at [email protected] to request investigation and data deletion.

23jl reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC guidelines, or PAGCOR regulatory requirements.

Material changes will be communicated to registered 23jl users via email notification or a prominent notice on the Platform at least seven (7) days before the change takes effect. The "Last Updated" date at the top of this Policy will be revised accordingly. Your continued use of 23jl following notification of material changes constitutes acceptance of the revised Policy.

For all data privacy matters — including access requests, correction requests, erasure requests, objections, complaints, or general privacy inquiries — please contact the 23jl Data Protection Officer: