1234jl Privacy Policy:
How We Protect Your Data

01 Introduction

1234jl is a PAGCOR-regulated online gaming platform proudly serving Filipino players across the Philippines — from Metro Manila and Cebu to Davao, Quezon City, and beyond. As a licensed operator, we are required to collect certain personal information from members to verify identity, process transactions, prevent fraud, and fulfil our obligations to the Philippine Amusement and Gaming Corporation (PAGCOR).

We recognise that your personal data belongs to you, and that trusting us with it is a significant responsibility. 1234jl is committed to handling your data with the highest standards of care, transparency, and security. This Policy tells you exactly what we do with your information — clearly, honestly, and in plain English.

02 Data Controller

1234jl acts as the Data Controller for all personal information collected from members and users of the platform. As Data Controller, 1234jl determines the purposes and means of processing your personal data, and is responsible for ensuring that such processing complies with the Data Privacy Act of 2012 and all applicable NPC issuances.

1234jl has appointed a Data Protection Officer (DPO) who is responsible for overseeing this Policy, monitoring compliance, and serving as the primary point of contact for members wishing to exercise their privacy rights. Contact details for our DPO are provided in Section 14 of this Policy.

03 Data We Collect

1234jl collects personal data through several channels, including account registration, KYC verification submissions, financial transactions, customer support interactions, and automated technical collection. The categories of personal data we collect are set out below:

04 How We Use Your Data

1234jl uses the personal data we collect only for lawful, specific, and legitimate purposes. The primary purposes for which we process your data are:

• Account Management: Creating and maintaining your 1234jl member account, verifying your identity at registration and throughout your membership, and enabling secure login access.
• KYC & Regulatory Compliance: Fulfilling our Know Your Customer (KYC), Anti-Money Laundering (AML), and Counter-Terrorism Financing (CTF) obligations as required by PAGCOR and Philippine law.
• Payment Processing: Processing deposits, withdrawals, and refunds via GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other supported payment channels in Philippine Peso (PHP).
• Gaming Operations: Delivering and improving game products, tracking betting activity for fairness audits, resolving disputes, and detecting fraudulent or collusive gameplay patterns.
• Responsible Gaming: Monitoring member activity for signs of problem gambling, enforcing self-exclusion and deposit limit settings, and verifying that all members meet the 21+ age requirement under Philippine law.
• Customer Support: Responding to inquiries, resolving complaints, and maintaining records of support interactions for quality and compliance purposes.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to members who have opted in to receive such communications. You may opt out at any time via your account notification settings.
• Platform Security: Detecting, preventing, and investigating unauthorised access, account takeovers, fraud, and other security incidents.
• Legal Obligations: Complying with court orders, law enforcement requests, PAGCOR reporting requirements, and any other legal obligation applicable to a licensed operator in the Philippines.

05 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 1234jl processes personal data on the following legal bases:

• Consent: You provide express consent to data collection and processing when you register your 1234jl account and accept this Privacy Policy. You may withdraw consent at any time, subject to the limitations described in Section 10.
• Contractual Necessity: Certain processing is required to perform the contract between you and 1234jl — for example, processing your deposits and withdrawals, or operating your gaming account.
• Legal Obligation: 1234jl is required by PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine authorities to collect and retain specific categories of member data. This processing does not require your consent but we will always be transparent about it.
• Legitimate Interests: Certain data processing activities — such as fraud detection, platform security, and responsible gaming monitoring — are necessary for the legitimate interests of 1234jl and its members, provided those interests are not overridden by your privacy rights.

06 Sharing Your Data

1234jl does not sell your personal data. We share your data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• PAGCOR and Philippine Government Authorities: As a condition of our gaming licence, 1234jl is required to submit member data, transaction records, and compliance reports to PAGCOR, the AMLC, the Bureau of Internal Revenue (BIR), and other Philippine regulatory bodies upon request or on a scheduled basis.
• Payment Service Providers: When you make a deposit or withdrawal, we share the minimum necessary data with your selected payment provider (e.g., GCash, PayMaya, BPI, BDO) to process the transaction securely.
• Identity Verification Partners: 1234jl uses third-party KYC and identity verification services to authenticate member identities and validate government-issued documents as required by our PAGCOR licence.
• Game Software Providers: Providers of the games available on 1234jl may receive anonymised or pseudonymised gameplay data for fair gaming audits, RNG certification, and performance analytics.
• IT and Security Service Providers: Third-party providers that host our infrastructure, provide cybersecurity monitoring, or support platform operations may process your data on our behalf under strict data processing agreements.
• Professional Advisors: Lawyers, accountants, auditors, and compliance consultants who are bound by professional confidentiality obligations may access member data where required for the provision of their services to 1234jl.

07 Data Retention

1234jl retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law and PAGCOR regulations:

• Account and Identity Data: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and Anti-Money Laundering regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the transaction date in accordance with AMLC reporting requirements and BIR tax record obligations.
• KYC Verification Documents: Retained for the duration of membership plus five (5) years following account closure.
• Gaming Activity Logs: Retained for a minimum of two (2) years from the date of the gaming session for dispute resolution and audit purposes.
• Customer Support Records: Retained for three (3) years from the date of the last interaction.
• Marketing Preferences: Retained until you withdraw your consent or opt out, after which marketing data is deleted within 30 days.

Upon the expiry of the applicable retention period, your personal data will be securely deleted or anonymised so that it can no longer be linked back to you as an individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

08 Security Measures

1234jl implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our key security measures include:

• SSL/TLS Encryption: All data transmitted between your device and the 1234jl platform is encrypted using 256-bit SSL/TLS technology, ensuring that your login credentials, financial details, and personal information cannot be intercepted in transit.
• Encrypted Data Storage: Sensitive data fields, including financial information and government ID numbers, are stored using strong encryption in our database systems.
• Access Controls: Access to member personal data is restricted on a strict need-to-know basis. 1234jl employees and contractors can only access the data required to perform their specific job functions.
• Two-Factor Authentication (2FA): 1234jl offers 2FA for all member accounts and requires it for certain sensitive account actions such as withdrawal requests and contact detail changes.
• Regular Security Audits: Our platform infrastructure is subject to regular third-party penetration testing and security audits to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: 1234jl maintains a data breach response plan and will notify affected members and the NPC within 72 hours of becoming aware of any personal data breach that poses a risk to member rights and freedoms.

09 Cookies & Tracking Technologies

1234jl uses cookies, web beacons, pixel tags, and similar tracking technologies on its platform to enhance your user experience, ensure platform security, and gather analytics data to improve our services. The types of cookies we use are:

• Strictly Necessary Cookies: These cookies are essential for the operation of the 1234jl platform. They enable core functions such as secure login session management, fraud prevention checks, and load balancing. These cookies cannot be disabled without affecting core platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymised data about how members use the 1234jl platform — which pages are visited most, how long sessions last, and where users encounter errors. This information helps us continuously improve the platform experience.
• Functionality Cookies: These cookies remember your preferences, such as your selected language, preferred game categories, and display settings, so that you do not need to reconfigure them on each visit.
• Responsible Gaming Cookies: These cookies support the delivery of session time reminders, reality check notifications, and deposit limit alerts as part of our responsible gaming commitments.

You can manage your cookie preferences at any time through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, and receive warnings before a cookie is placed. Please note that disabling strictly necessary cookies may affect your ability to log in and use certain features of the 1234jl platform.

10 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), all 1234jl members have the following rights with respect to their personal data:

• Right to be Informed: You have the right to know what personal data 1234jl holds about you, how it is being used, and with whom it is shared. This Privacy Policy is our primary mechanism for providing that transparency.
• Right of Access: You may request a copy of the personal data that 1234jl holds about you. We will respond to verified access requests within 15 working days of receipt.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. You may update most contact details directly from within your account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. Please note that certain data must be retained for the mandatory periods described in Section 7 regardless of an erasure request.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though such objections will be weighed against our regulatory obligations.
• Right to Data Portability: You may request that 1234jl provide your personal data in a structured, commonly used, machine-readable format so that it can be transferred to another service provider.
• Right to Lodge a Complaint: If you believe that 1234jl has breached your privacy rights, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 14. We may need to verify your identity before processing any privacy rights request.

11 Minors & Age Policy

The 1234jl platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law and PAGCOR licensing conditions. 1234jl does not knowingly collect or process personal data from individuals under the age of 21.

All members are required to provide proof of age during the KYC verification process. If 1234jl becomes aware that a member account has been registered by or on behalf of a person under 21 years of age, the account will be immediately suspended, all associated balances will be frozen pending investigation, and the matter will be reported to PAGCOR as required by our regulatory obligations.

12 International Data Transfers

As an online gaming platform, certain data processing activities may involve the transfer of your personal data to servers or service providers located outside the Philippines. Where such international transfers occur, 1234jl ensures that adequate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012 and NPC guidelines.

These safeguards may include contractual clauses that impose data protection obligations on overseas recipients equivalent to those applicable in the Philippines, or reliance on the recipient country's adequacy determination by the NPC. 1234jl will not transfer your personal data to a jurisdiction that does not offer an adequate level of data protection without first obtaining your explicit consent or ensuring appropriate contractual protections are in place.

13 Changes to This Policy

1234jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, or our internal data practices. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this page;
• Post a notice on the 1234jl platform homepage and within the member account area;
• Where required by law, notify affected members directly via email or in-platform message prior to the changes taking effect.

Your continued use of the 1234jl platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this Policy, you should cease using the platform and contact our Data Protection Officer to exercise your data rights, including requesting account closure.

We encourage you to review this Privacy Policy periodically to stay informed about how 1234jl collects, uses, and protects your personal information. The most current version of this Policy is always available at https://1234jl.net/privacy-policy.

14 Contact & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise any of your data rights under the Philippine Data Privacy Act, or need to report a potential privacy concern, please contact our Data Protection Officer through the following channels:

• Email: [email protected] (please include "Privacy Rights Request" or "DPO Inquiry" in your subject line)
• Live Chat: Available 24/7 through the 1234jl platform after logging in to your member account.
• Platform Helpdesk: Submit a support ticket via the Help section within your account dashboard, selecting "Privacy & Data Protection" as the inquiry category.

We aim to acknowledge all privacy-related inquiries within two (2) business days and to resolve substantive requests within fifteen (15) business days. Complex requests involving large volumes of data or third-party coordination may take longer, in which case we will keep you informed of our progress.

If you are not satisfied with our response to your privacy inquiry, you have the right to escalate the matter directly to the National Privacy Commission (NPC) of the Philippines. Information on how to file an NPC complaint is available on the NPC's official website.