bbb39jl Privacy Policy

1.1 Identity Data

Full legal name, date of birth, nationality, government-issued identification number (e.g., Philippine National ID, passport, driver's licence, SSS/GSIS number), and a copy of your identification document where required for KYC verification.

1.2 Contact Data

Residential address (including barangay, city/municipality, province, and ZIP code), email address, and Philippine mobile number.

1.3 Financial Data

Payment method details (GCash account number, Maya account number, bank account details, or debit card details), transaction history including deposits, withdrawals, and wagers, and account balance information.

1.4 Gaming Activity Data

Game history, betting patterns, session duration, login and logout timestamps, bonus usage, and responsible gaming tool activations (e.g., deposit limits, self-exclusion requests).

1.5 Technical Data

IP address, device type and operating system, browser type and version, screen resolution, referring URL, pages visited on the bbb39jl Platform, and session identifiers.

1.6 Communications Data

Records of your communications with bbb39jl customer support, including live chat transcripts, email correspondence, and any feedback or complaints submitted through the Platform.

2.1 Directly From You

The majority of personal data bbb39jl holds about you is provided directly by you during the account registration process, identity verification (KYC), deposit and withdrawal transactions, completion of responsible gaming forms, and communications with our support team.

2.2 Automatically

When you access and use the bbb39jl Platform, we automatically collect certain technical data through cookies, web beacons, log files, and similar tracking technologies. This includes your IP address, device information, and browsing behaviour on the Platform. See Section 10 (Cookies) for more detail.

2.3 From Third Parties

bbb39jl may receive personal data about you from third-party identity verification providers, payment processors (such as GCash, Maya, and partner banks), fraud prevention services, and analytics providers. All third-party data sharing is conducted under appropriate data processing agreements.

4.1 Contractual Necessity

Much of the personal data bbb39jl processes is necessary for the performance of the contract between you and bbb39jl — specifically, to provide you with access to the Platform, process your transactions, and deliver the gaming services you have requested.

4.2 Legal Obligation

bbb39jl is required by applicable law — including the Philippine Data Privacy Act, Anti-Money Laundering Act (AMLA), and gaming regulations — to collect and retain certain personal data. Processing for these purposes is mandatory and cannot be opted out of while you maintain an active bbb39jl account.

4.3 Legitimate Interests

Where processing is not strictly required by contract or law, bbb39jl may process your data on the basis of its legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and improving the quality of our services. We ensure that our legitimate interests do not override your fundamental rights and freedoms.

4.4 Consent

For certain processing activities — such as sending you marketing communications or using non-essential cookies — bbb39jl will seek your explicit consent. You may withdraw your consent at any time by updating your account preferences or contacting our support team, without affecting the lawfulness of processing carried out prior to withdrawal.

5.1 Service Providers

bbb39jl engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, Maya, partner banks), identity verification providers, cloud hosting and infrastructure providers, customer support platforms, and analytics services. These providers are contractually bound to process your data only on bbb39jl's instructions and in accordance with applicable data protection law.

5.2 Regulatory and Law Enforcement Authorities

bbb39jl may disclose your personal data to government agencies, regulatory bodies, or law enforcement authorities where required to do so by law, court order, or regulatory directive — including disclosures required under the Philippine Anti-Money Laundering Act (AMLA) and gaming regulations.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of bbb39jl's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Policy that result from it.

5.4 With Your Consent

bbb39jl may share your data with third parties in any other circumstances where you have given your explicit prior consent to such sharing.

6.1 Retention Periods

bbb39jl retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. In general:

• Account and identity data is retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements;
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Customer support communications are retained for three (3) years from the date of the interaction;
• Technical and analytics data is retained in anonymised or aggregated form for up to two (2) years.

6.2 Deletion

Upon expiry of the applicable retention period, bbb39jl will securely delete or anonymise your personal data. Where deletion is not immediately possible due to technical constraints (for example, data stored in backup archives), bbb39jl will isolate the data from further processing until deletion is feasible.

7.1 Technical Safeguards

bbb39jl implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include Transport Layer Security (TLS) encryption for all data in transit, encryption of sensitive data at rest, access controls and role-based permissions for internal systems, regular security audits and vulnerability assessments, and multi-factor authentication for administrative access.

7.2 Organisational Safeguards

Access to your personal data within bbb39jl is restricted to employees and contractors who have a legitimate need to access it in the course of their duties. All personnel with access to personal data are subject to confidentiality obligations and receive regular data protection training.

7.3 Data Breach Response

In the event of a personal data breach that poses a risk to your rights and freedoms, bbb39jl will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay where the breach is likely to result in a high risk to their rights. Notification will include a description of the nature of the breach, the data affected, and the steps bbb39jl is taking to address it.

Right to Access

You have the right to request a copy of the personal data bbb39jl holds about you, along with information about how it is being processed.

Right to Rectification

You have the right to request that bbb39jl correct any inaccurate or incomplete personal data held about you. You may update certain information directly through your account settings.

Right to Erasure

You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been unlawfully processed. This right is subject to bbb39jl's legal retention obligations.

Right to Object / Restrict Processing

You have the right to object to or request restriction of the processing of your personal data in certain circumstances, including where processing is based on legitimate interests or where you contest the accuracy of the data.

Right to Data Portability

Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller.

9.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the bbb39jl Platform. They allow the Platform to recognise your device, remember your preferences, and provide a more personalised experience. bbb39jl also uses similar technologies such as web beacons and local storage objects.

9.2 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Platform to function. These cannot be disabled and do not require your consent.
• Functional Cookies: Remember your preferences (e.g., language, game settings) to improve your experience.
• Analytics Cookies: Help bbb39jl understand how players use the Platform so we can improve it. Data collected is aggregated and anonymised where possible.
• Session Cookies: Temporary cookies that expire when you close your browser, used to maintain your login session.

9.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the bbb39jl Platform. For strictly necessary cookies, no opt-out is available as they are essential to the operation of the service.

10.1 No Services for Persons Under 21

The bbb39jl Platform is strictly intended for persons aged 21 years and above. bbb39jl does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not use the Platform or provide any personal data to bbb39jl.

If bbb39jl becomes aware that it has inadvertently collected personal data from a person under 21, it will take immediate steps to delete that data and close the associated account. If you believe bbb39jl may have collected data from a minor, please contact us immediately at [email protected].

11.1 Policy Updates

bbb39jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the services we offer. The date of the most recent revision is indicated at the top of this page. Where changes are material, bbb39jl will notify registered players via email or in-platform notification prior to the changes taking effect.

Your continued use of the bbb39jl Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how bbb39jl protects your data.

12.1 Data Protection Officer

bbb39jl has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection law. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact our DPO:

Data Protection Officer — bbb39jl

Email: [email protected]

General Support: [email protected]

We aim to respond to all privacy-related enquiries within thirty (30) calendar days of receipt. For complex requests, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it.

12.2 National Privacy Commission

If you are not satisfied with bbb39jl's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing the Data Privacy Act of 2012.