25jl Privacy Policy

1. Introduction

25jl ("the Company," "we," "us," "our") operates the online gaming platform accessible at 25jl.one, serving Filipino players across Manila, Cebu, Davao, Quezon City, Makati, and throughout the Philippines. We are committed to protecting the privacy and personal data of all individuals who interact with our platform, whether as registered players, visitors, or support contacts.

This Privacy Policy constitutes part of 25jl's legal framework and should be read in conjunction with our Terms & Conditions. By registering an account at 25jl or otherwise using the platform, you acknowledge that you have read, understood, and agreed to the data practices described in this Policy.

As a PAGCOR-licensed operator, 25jl is subject to specific data collection, retention, and reporting obligations under Philippine gaming regulations, the Anti-Money Laundering Act (AMLA), and related legislation. Certain data processing activities described in this Policy are carried out in compliance with these regulatory obligations and cannot be opted out of by individual players.

2. Personal Data We Collect

25jl collects the following categories of personal data, the collection of which varies depending on how you use the platform:

We do not intentionally collect sensitive personal data beyond what is strictly required for age verification and identity documentation. We do not collect racial, ethnic, religious, political, or biometric data beyond the photograph that may appear on your identity document.

3. How We Collect Your Personal Data

25jl collects personal data through the following methods:

• Direct Provision: Data you provide when registering your 25jl account, completing KYC, making deposits, requesting withdrawals, contacting support, or completing surveys and promotions;
• Automated Collection: Technical data collected automatically through cookies, web beacons, log files, and similar tracking technologies when you access the 25jl platform;
• Third-Party Payment Processors: Transaction confirmation data from GCash, Maya, BPI, BDO, Metrobank, and other payment providers when you initiate deposits or withdrawals;
• Identity Verification Services: Verification data from third-party KYC service providers used to authenticate government-issued identification documents;
• Fraud Prevention Services: Risk signals and device fingerprint data from fraud detection partners to protect the platform and our players from unauthorized account access.

4. How We Use Your Personal Data

25jl uses the personal data we collect for the following purposes:

• Account Management: Creating, maintaining, and administering your 25jl account, including processing login requests, password resets, and account settings changes;
• Identity and Age Verification: Conducting KYC checks to confirm your identity and verify that you meet the PAGCOR-mandated minimum age requirement of 21 years;
• Payment Processing: Facilitating deposits and withdrawals via your chosen payment method, and maintaining transaction records as required by Philippine financial regulations;
• Regulatory Compliance: Meeting obligations under PAGCOR licensing conditions, AMLA reporting requirements, the Data Privacy Act, and other applicable Philippine laws;
• Platform Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and other security threats;
• Responsible Gaming: Monitoring gaming activity to identify potential problem gambling indicators, and administering deposit limits and self-exclusion requests;
• Customer Support: Responding to your support inquiries, investigating disputes, and providing assistance with account issues;
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in — you may unsubscribe at any time;
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve game selection, site performance, and the overall 25jl experience.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173), 25jl processes personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and 25jl — including account creation, gaming services, and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AMLA obligations, NPC directives, and other applicable Philippine laws;
• Legitimate Interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving 25jl services — where our interests do not override your privacy rights;
• Consent: Marketing communications and non-essential cookies, which you may withdraw at any time without affecting your ability to use 25jl's core services.

6. Disclosure and Sharing of Personal Data

25jl does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your data with the following categories of recipients, strictly for the purposes described in this Policy:

• PAGCOR and Regulatory Authorities: As required by our gaming license and applicable law, including mandatory reporting of suspicious transactions to the Anti-Money Laundering Council (AMLC);
• Payment Service Providers: GCash, Maya, BPI, BDO, Metrobank, and other payment processors, solely to facilitate transactions you have initiated;
• Identity Verification Providers: Third-party KYC and document verification services engaged to authenticate your identity documents;
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform maintenance providers operating under strict data processing agreements;
• Game Software Providers: Game studios and platform providers may receive session data necessary to deliver game functionality — such providers are contractually bound to data protection standards;
• Law Enforcement: Philippine law enforcement agencies, courts, or government bodies where disclosure is required by valid legal process or court order.

All third-party service providers engaged by 25jl are contractually required to maintain appropriate data security measures and to process personal data only for the specific purposes authorized by 25jl.

7. Data Retention

25jl retains personal data for as long as necessary to fulfil the purposes for which it was collected, and in accordance with applicable legal and regulatory retention requirements. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your 25jl account and for a minimum of five (5) years following account closure, as required by PAGCOR and AMLA regulations;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with AMLA reporting obligations;
• Gaming Activity Logs: Retained for a minimum of three (3) years for PAGCOR compliance purposes and dispute resolution;
• Support Communications: Retained for two (2) years from the date of the interaction;
• Marketing Consent Records: Retained until consent is withdrawn, plus six (6) months to demonstrate compliance.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymized. Anonymized aggregate data may be retained indefinitely for analytical purposes.

8. Data Security

25jl implements appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 25jl platform;
• Encryption of sensitive data at rest, including identity documents and financial account references;
• Role-based access controls limiting employee access to personal data strictly to job function requirements;
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent security firms;
• Multi-factor authentication requirements for administrative platform access;
• Staff training on data protection obligations and information security best practices.

In the event of a personal data breach that poses a risk to your rights and freedoms, 25jl will notify the National Privacy Commission (NPC) and affected players in accordance with the Data Privacy Act's breach notification requirements.

9. Cookies and Tracking Technologies

25jl uses cookies and similar tracking technologies to operate the platform and improve your experience. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for platform operation — login sessions, security tokens, and preference settings. These cannot be disabled without impairing platform functionality.
• Performance Cookies: Collect anonymized data on page usage and platform performance to help us improve 25jl. No personally identifying data is stored in these cookies.
• Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, including session hijacking and unauthorized account access attempts.
• Marketing Cookies: Used to display relevant promotional content to players who have consented to marketing communications. These may be disabled without affecting core platform access.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may prevent you from accessing parts of the 25jl platform. For marketing and performance cookies, your consent is obtained on first platform visit and can be withdrawn at any time.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act (RA 10173), you have the following rights with respect to your personal data held by 25jl:

• Right to be Informed: To be notified about how your data is collected and processed — fulfilled by this Policy;
• Right to Access: To request a copy of the personal data 25jl holds about you;
• Right to Rectification: To request correction of inaccurate or incomplete personal data in your 25jl records;
• Right to Erasure (Right to be Forgotten): To request deletion of personal data where no longer necessary, subject to legal retention obligations under PAGCOR and AMLA requirements;
• Right to Data Portability: To receive your personal data in a structured, commonly used format;
• Right to Object: To object to specific processing activities, particularly marketing communications;
• Right to Lodge a Complaint: To file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, contact 25jl's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will respond within fifteen (15) business days of receipt.

11. Minors and Age Restriction

The 25jl platform is strictly for persons aged twenty-one (21) years and above, as required by PAGCOR regulations. We do not knowingly collect personal data from individuals under 21 years of age. Age verification is a mandatory step in the 25jl registration and KYC process.

If 25jl discovers or is notified that personal data has been collected from an individual under the minimum age requirement, such data will be deleted, the account will be closed, and any deposited funds will be returned in accordance with applicable law.

If you are a parent or guardian and believe your minor child has registered with 25jl, please contact our support team immediately at [email protected]. We take underage access extremely seriously and will act promptly upon credible notification.

12. Changes to This Privacy Policy

25jl reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or platform features. Material changes will be communicated to registered players via email notification or a prominent notice on the platform at least seven (7) days before the revised Policy takes effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the 25jl platform following the effective date of any revision constitutes your acceptance of the updated Privacy Policy. If you do not agree to the revised Policy, you should cease using the platform and request account closure.

13. Contact Our Data Protection Officer

25jl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. For any data privacy inquiries, requests, or concerns, please contact:

• Email: [email protected] — Subject line: "Data Privacy Request"
• Response Time: Within 15 business days for written requests
• Live Support: Available 24/7 via the in-platform chat for general privacy inquiries

You also have the right to file a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe 25jl has not adequately addressed your privacy concern. Information on NPC complaint procedures is available on the NPC's official government website.