Privacy Policy – How 20jl Handles Your Personal Data

1. Introduction

This Privacy Policy ("Policy") describes how 20jl ("we", "us", "our", "the Platform") collects, uses, discloses, and protects personal information obtained from individuals ("you", "the User", "Data Subject") who access 20jl through 20jl.org or any associated interface.

By registering an account or using any service on 20jl, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal information as described herein. If you do not consent, you must not use the 20jl platform.

This Policy applies to all personal data collected in connection with your use of 20jl, including account registration, deposits and withdrawals, gameplay, customer support interactions, and promotional participation.

2. Data Controller

20jl is the personal information controller responsible for the collection and processing of your personal data as described in this Policy. As a PAGCOR-regulated gaming operator, 20jl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Policy.

3. Personal Data We Collect

3.1 Registration Data

When you create a 20jl account, we collect: full legal name, date of birth, nationality, residential address, email address, mobile number, and username. This information is required to verify your identity and eligibility to use 20jl services.

3.2 Identity Verification (KYC) Data

As required by PAGCOR regulations and anti-money laundering obligations, we collect and verify government-issued identification documents (e.g., Philippine Statistics Authority national ID, passport, driver's license), proof of address, and selfie photographs for identity confirmation.

3.3 Financial Data

We collect payment method information necessary to process deposits and withdrawals, including GCash mobile numbers, PayMaya account details, bank account numbers (BPI, BDO, Metrobank), and transaction history. We do not store full card numbers; card-based transactions are processed by PCI-DSS compliant payment processors.

3.4 Usage Data

We automatically collect technical and behavioral data when you interact with 20jl, including: IP address, device type and operating system, browser type, pages visited, game sessions played, bet amounts and outcomes, session duration, and login timestamps.

3.5 Communications Data

Records of communications between you and 20jl customer support — including live chat transcripts, email correspondence, and support ticket content — are retained for quality assurance, dispute resolution, and regulatory compliance purposes.

4. How We Use Your Personal Data

20jl processes your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your 20jl account
• Identity verification: Confirming your eligibility including age (21+) and jurisdictional compliance
• Transaction processing: Facilitating deposits, withdrawals, and bonus credits in Philippine Peso
• Regulatory compliance: Meeting PAGCOR reporting requirements, anti-money laundering (AMLA) obligations, and tax reporting requirements
• Fraud prevention: Detecting and preventing unauthorized account access, bonus abuse, and financial fraud
• Responsible gaming: Monitoring gameplay patterns to identify indicators of problem gambling and enforcing self-exclusion requests
• Customer support: Responding to your queries, complaints, and support requests
• Service improvement: Analyzing platform usage to improve game offerings, payment flows, and user experience
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates, where you have provided consent

5. Legal Basis for Processing

20jl processes your personal data under the following legal bases as recognized under the Data Privacy Act of 2012:

• Consent: You have given specific, informed consent for marketing communications and optional data uses
• Contractual necessity: Processing is necessary to fulfill the 20jl user agreement and provide services you have requested
• Legal obligation: Processing is required to comply with PAGCOR regulations, AMLA reporting obligations under Republic Act No. 9160, and other applicable Philippine law
• Legitimate interests: Processing is necessary for 20jl's legitimate interests in fraud prevention, platform security, and responsible gaming enforcement, where these interests are not overridden by your rights

6. Sharing Your Personal Data

6.1 Service Providers

20jl shares personal data with trusted third-party service providers who assist in operating the platform, including payment processors (GCash, PayMaya, banking partners), identity verification services, game software providers, IT infrastructure and hosting providers, and customer support platform vendors. All third-party processors are required to handle your data in accordance with this Policy and applicable Philippine data privacy law.

6.2 Regulatory Authorities

20jl is required by law to share certain personal and transactional data with PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other Philippine government authorities upon lawful request or as mandated by applicable regulations.

6.3 No Sale of Data

20jl does not sell, rent, or trade your personal data to any third party for their own marketing, advertising, or commercial purposes. This is an absolute commitment.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 20jl's business assets, your personal data may be transferred to the successor entity, subject to the same or equivalent privacy protections. You will be notified of any such transfer that materially affects your rights under this Policy.

7. Cookies & Tracking Technologies

20jl uses cookies and similar tracking technologies to operate the platform effectively. The types of cookies we use include:

• Essential cookies: Required for the platform to function. These include session authentication cookies, security tokens, and load balancing cookies. These cannot be disabled without preventing platform use.
• Analytics cookies: Used to understand how users navigate 20jl, which pages are visited most, and where errors occur. Data is aggregated and anonymized where possible.
• Preference cookies: Store your platform preferences such as language settings, display options, and previously visited game categories.
• Marketing cookies: Used only where you have provided explicit consent to receive targeted promotional communications.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies may affect certain platform features but will not prevent access to core 20jl services.

8. Data Retention

20jl retains your personal data for the following periods:

• Account data: For the duration of your active 20jl account, plus a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA requirements
• Transaction records: Minimum five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act
• KYC documents: For the duration of account activity plus five (5) years post-closure
• Customer support records: Three (3) years from the date of the last interaction
• Marketing consent records: Until consent is withdrawn, plus two (2) years as proof of consent

Following the expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with 20jl's data destruction procedures.

9. Data Security

20jl implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit
• Encryption of sensitive data at rest using industry-standard algorithms
• Role-based access controls limiting data access to authorized 20jl personnel only
• Multi-factor authentication for all internal system access
• Regular security audits and penetration testing by independent third parties
• Real-time intrusion detection and monitoring systems
• Mandatory data security training for all 20jl staff with access to personal data

Despite these measures, no system is entirely immune to security risks. In the event of a data breach that poses risk to your rights and freedoms, 20jl will notify you and the National Privacy Commission within 72 hours as required by RA 10173.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 20jl:

To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Subject Rights Request." We will respond within thirty (30) days. Identity verification will be required before processing rights requests.

11. Children's Privacy

20jl does not knowingly collect personal data from individuals under the age of 21. The platform is strictly restricted to adults who meet the minimum age requirement under Philippine gaming law. If we become aware that personal data has been collected from an individual under 21 years of age, we will immediately delete such data and close the associated account. Parents or guardians who believe a minor has accessed 20jl should contact us immediately at [email protected].

12. Third-Party Services

The 20jl platform integrates with third-party services necessary for its operation, including payment gateways (GCash, PayMaya, banking networks), game software providers, and identity verification services. When you interact with these third-party services through 20jl, those providers may collect additional data subject to their own privacy policies. 20jl is not responsible for the data practices of third-party providers beyond its contractual obligations to ensure adequate data protection standards are maintained.

20jl does not embed third-party social media tracking pixels or advertising SDKs that would share your gaming activity with social media platforms without your explicit consent.

13. Changes to This Privacy Policy

20jl may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform operations. Material changes will be communicated to registered users via email to the address associated with your 20jl account and through a prominent notice on the 20jl website prior to the change taking effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of 20jl after notification of material changes constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you must discontinue use of 20jl and may request account closure.

14. Contact & Data Protection Officer

For all privacy-related inquiries, data subject rights requests, or concerns regarding 20jl's data handling practices, please contact our Data Protection Officer:

20jl is committed to resolving data privacy concerns promptly and in good faith. We take every inquiry seriously and treat all data subject rights requests with appropriate urgency and confidentiality.