625jl Privacy Policy – How We Protect Your Personal Data

1. About This Policy and the Data Controller

This Privacy Policy describes how 625jl ("625jl," "we," "our," or "us") — the operator of the online gaming platform accessible at https://625jl.net — collects, uses, stores, discloses, and otherwise processes personal data in connection with your use of the 625jl platform and related services (collectively, the "Platform").

625jl acts as the data controller in respect of personal data collected through the Platform. As a PAGCOR-regulated entity, 625jl processes personal data in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission ("NPC").

By registering an account with 625jl or using the Platform in any capacity, 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

625jl collects the following categories of personal data, depending on your level of interaction with the Platform:

625jl does not knowingly collect sensitive personal information as defined under the DPA (such as health data, racial or ethnic origin, political affiliations, or religious beliefs) unless specifically required for responsible gaming interventions or legal compliance, in which case appropriate safeguards apply.

3. Legal Basis and Purposes of Processing

625jl processes your personal data on the following legal bases as provided under Section 12 and Section 13 of the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform our obligations under the Terms and Conditions you accepted upon registration — including account management, game delivery, and payment processing;
• Legal Obligation: Processing required to comply with 625jl's PAGCOR licensing obligations, Anti-Money Laundering Act (AMLA) reporting requirements, and NPC data governance directives;
• Legitimate Interest: Processing for fraud detection, security monitoring, responsible gaming interventions, and Platform improvement, where such interests are not overridden by your privacy rights;
• Consent: Processing for optional services such as marketing communications, where you have provided explicit consent at the time of registration or thereafter.

4. How We Use Your Personal Data

625jl uses your personal data for the following specific purposes:

• To create, verify, operate, and maintain your 625jl account;
• To process deposits and withdrawals through Philippine payment channels (GCash, Maya, BPI, BDO, Metrobank, InstaPay, PesoNet, 7-Eleven CLiQQ, GrabPay, QR Ph);
• To conduct Know Your Customer (KYC) verification as required by PAGCOR and AMLA;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited conduct;
• To provide customer support via live chat and email;
• To administer responsible gaming interventions, including responding to self-exclusion requests and deposit limit updates;
• To send transactional communications (deposit confirmations, withdrawal notifications, security alerts) — these are non-optional service messages;
• To send promotional communications about 625jl offers and new games, where you have provided consent to receive such communications (you may withdraw consent at any time);
• To fulfill any legal reporting obligations to PAGCOR, the AMLC, the NPC, or other competent Philippine authorities;
• To improve Platform functionality, game recommendations, and user experience through aggregate and anonymized analytics.

5. Disclosure of Personal Data to Third Parties

625jl does not sell or rent your personal data to any third party. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Processors: GCash (Mynt), Maya (PayMaya Philippines), BancNet, InstaPay operators, and other Philippine payment intermediaries — for transaction processing only;
• KYC and Identity Verification Providers: Licensed third-party identity verification services engaged to assist with PAGCOR-mandated KYC procedures;
• Game Content Providers: Software providers such as JILI, Pragmatic Play, and PG Soft receive necessary technical session data to deliver game services — they do not receive your identity or financial data;
• Cloud and Hosting Infrastructure: Data center and cloud service providers operating the servers on which the 625jl Platform is hosted, bound by data processing agreements;
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the NPC, and other Philippine government bodies where disclosure is required by law or regulatory mandate.

All third-party service providers engaged by 625jl are contractually required to process personal data only as instructed by 625jl, to implement appropriate technical and organizational security measures, and to comply with the Data Privacy Act.

6. Cookies and Tracking Technologies

625jl uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for Platform functionality including session management, login authentication, and security. These cannot be disabled without impairing Platform access;
• Performance Cookies: Collect anonymized data about how users navigate the Platform, enabling 625jl to identify and fix technical issues and improve load performance;
• Functional Cookies: Remember your preferences such as language settings and display preferences to provide a more personalized experience;
• Analytics Cookies: Aggregated, anonymized usage data used to understand Platform engagement patterns and inform development priorities. No individual-level profiling is performed.

You may manage cookie preferences through your browser settings. Note that disabling essential cookies will affect Platform functionality including the ability to maintain a logged-in session.

7. Data Security Measures

625jl implements technical and organizational security measures appropriate to the risk level of the data we process, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and 625jl's servers;
• Encryption at rest for stored personal data and KYC documents;
• Role-based access controls ensuring 625jl personnel can access only the data necessary for their specific job functions;
• Multi-factor authentication requirements for all staff with access to production data systems;
• Regular independent penetration testing and security audits;
• Automated anomaly detection and intrusion prevention systems;
• A documented incident response procedure aligned with NPC breach notification requirements (mandatory reporting of qualifying breaches within 72 hours).

8. Data Retention

625jl retains personal data for the following periods, after which data is securely deleted or anonymized:

• Account and KYC Data: For the duration of your account plus five (5) years following account closure, as required by PAGCOR AML compliance obligations;
• Transaction and Gaming Records: Five (5) years from the date of the transaction, in compliance with AMLA record-keeping requirements;
• Support Communications: Two (2) years from the date of the interaction, unless a related dispute or regulatory inquiry extends the retention period;
• Technical and Log Data: Ninety (90) days, unless flagged for fraud investigation or security review;
• Marketing Consent Records: Until consent is withdrawn, plus one (1) year thereafter as evidence of the original consent.

9. Cross-Border Data Transfers

Some of 625jl's third-party service providers — including game software providers and cloud infrastructure operators — may process personal data outside the Republic of the Philippines. Where such cross-border transfers occur, 625jl ensures that:

• The recipient country offers an adequate level of data protection, or;
• Appropriate contractual safeguards (such as standard contractual clauses approved by the NPC) are in place to ensure your data receives equivalent protection to that afforded under Philippine law.

Cross-border transfers are limited to those strictly necessary for Platform operations and are conducted only with service providers bound by data processing agreements meeting DPA standards.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 625jl. All rights may be exercised by contacting 625jl's Data Protection Officer at the contact details in Section 13.

625jl will respond to all data privacy rights requests within thirty (30) calendar days of receipt. If a request is complex or high in volume, we may extend this period by up to sixty (60) additional days, with written notice of the extension.

11. Children's Privacy

The 625jl Platform is strictly prohibited for persons under 21 years of age in accordance with Philippine law and PAGCOR regulations. 625jl does not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from an underage individual, we will immediately close the associated account, delete all related personal data, and forfeit any balance in the account in accordance with our Terms and Conditions.

If you believe a minor has registered an account on 625jl, please contact our support team immediately at the contact details in Section 13.

12. Changes to This Privacy Policy

625jl reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. Where material changes are made, 625jl will provide advance notice to registered account holders via email to the registered email address or via an in-platform notification.

The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. Your continued use of the 625jl Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this page periodically.

13. How to Contact Us and the NPC

For any questions, concerns, or data privacy rights requests, please contact 625jl's Data Protection Officer through the following channels:

• 24/7 Live Chat: Available on the 625jl Platform after login
• Email: [email protected] (subject line: "Data Privacy Request")