Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 12jl (the "Company," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the 12jl online gaming platform, including the website at 12jl.net and any associated mobile applications (collectively, the "Platform").

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. By registering for an account or using the 12jl Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which together govern your use of the 12jl Platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, 12jl acts as the personal information controller in respect of the personal data it collects and processes in connection with the operation of the Platform. The Company is responsible for ensuring that personal data is processed lawfully, fairly, and transparently in accordance with applicable Philippine data protection law.

Where 12jl engages third-party service providers to process personal data on its behalf, such providers act as personal information processors and are contractually bound to process data only in accordance with the Company's instructions and applicable law.

3. Data We Collect

12jl collects the following categories of personal data in connection with the operation of the Platform:

3.1 Identity & Registration Data

• Full legal name as it appears on a government-issued identification document
• Date of birth (for age verification — players must be 21 years or older)
• Gender (where provided voluntarily)
• Nationality and country of residence
• Government-issued ID number and document type (e.g., Philippine passport, SSS, UMID, driver's license)

3.2 Contact Data

• Email address
• Mobile phone number (Philippine mobile numbers accepted, e.g., Globe, Smart, DITO)
• Residential address, including barangay, city or municipality, province, and postal code

3.3 Financial Data

• GCash account number or registered mobile number
• PayMaya / Maya wallet details
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where used for transactions
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references

3.4 Gaming Activity Data

• Game session history, including games played, wager amounts, and outcomes
• Account balance history
• Bonus and promotion usage records
• Responsible gaming tool settings (deposit limits, session reminders, self-exclusion status)

3.5 Technical & Device Data

• IP address and approximate geolocation derived therefrom
• Device type, operating system, and browser type and version
• Unique device identifiers
• Log data, including access times, pages visited, and error reports

3.6 Communications Data

• Records of communications between you and 12jl customer support, including live chat transcripts and email correspondence
• Survey responses and feedback submitted voluntarily through the Platform

4. How We Collect Data

12jl 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 and device data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment confirmation data from GCash, PayMaya, and banking partners.
• Regulatory sources: Information received from Philippine regulatory authorities in connection with compliance obligations, including self-exclusion registers.

5. How We Use Your Data

12jl uses your personal data for the following purposes:

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, 12jl processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML/CTF obligations, KYC requirements, and regulatory reporting duties.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• 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.

7. Sharing Your Data

12jl does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your transactions.
• KYC and identity verification providers: Third-party providers engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention and AML partners: Service providers engaged to screen transactions and detect prohibited conduct.
• Technology and infrastructure providers: Cloud hosting, data storage, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Philippine government agencies, including the National Privacy Commission, and law enforcement bodies, where disclosure is required by law or court order.
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third-party processors engaged by 12jl are contractually required to implement appropriate technical and organizational security measures and to process personal data only in accordance with our instructions and applicable Philippine data protection law.

8. Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 12jl Platform. They help us recognize your device, maintain your session, remember your preferences, and analyze how the Platform is used.

8.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled without affecting core functionality such as login sessions and security features.
• Functional cookies: Remember your preferences such as language settings and display options to improve your experience on 12jl.
• Analytics cookies: Collect anonymized data about how players use the Platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Marketing cookies: Used to deliver relevant promotional content where you have consented. You may opt out of marketing cookies at any time through your account settings.

8.3 Managing Cookies

You may control cookie settings through your browser preferences. Please note that disabling strictly necessary cookies may impair your ability to use certain features of the 12jl Platform, including logging in and accessing your account balance.

9. Data Retention

12jl retains personal data for the following periods, after which data is securely deleted or irreversibly anonymized:

• 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 AML record-keeping requirements under Philippine law.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations.
• Gaming activity data: Retained for three (3) years from the date of the relevant gaming session, unless a longer period is required for dispute resolution or regulatory purposes.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless the matter remains unresolved.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of compliance.

Where retention beyond these periods is required by a court order, regulatory direction, or ongoing legal proceedings, 12jl will retain the relevant data until the matter is resolved.

10. Data Security

12jl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These 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
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular security audits and penetration testing of Platform infrastructure
• Multi-factor authentication requirements for administrative access to data systems
• Incident response procedures for detecting, reporting, and managing personal data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 12jl will notify the National Privacy Commission and affected players in accordance with the timeframes prescribed by the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

While 12jl takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorized access to your account.

11. 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 12jl:

• Right to be informed: The right to be notified of how your personal data is collected and processed, as set out in this Policy.
• Right of access: The right to request a copy of the personal data 12jl holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update certain information directly through your account settings.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal 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, and machine-readable format where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact the 12jl Data Privacy Officer using the contact details in Section 15 of this Policy. We will respond to verified requests within thirty (30) days, as required by applicable law.

12. Children & Minors

The 12jl Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine regulations governing online gaming. 12jl 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 the age of 21 without appropriate verification, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact us immediately using the details in Section 15.

Account holders are responsible for ensuring that no minor accesses the Platform through their account. 12jl recommends the use of parental control software to prevent minors from accessing online gaming platforms. For more information, visit our Responsible Gaming page.

13. Third-Party Services

The 12jl Platform may contain links to or integrations with third-party services, including payment gateways such as GCash and PayMaya. This Policy applies only to data processed by 12jl directly. When you interact with a third-party service, that service's own privacy policy governs the collection and use of your data.

12jl is not responsible for the privacy practices of third-party services and encourages you to review their respective privacy policies before providing any personal information.

14. Policy Amendments

12jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. The date of the most recent revision is indicated at the top of this page.

Where changes are material, we will notify registered players via the email address on file or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the 12jl Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how 12jl protects your personal data.

15. Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 12jl, please contact our Data Privacy Officer:

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. General support inquiries may also be directed to our customer support team at [email protected].