17jl Privacy Policy

1 Who We Are

17jl is the operator of the online gaming platform accessible at 17jl.org, operating under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR). For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173), 17jl acts as the Personal Information Controller with respect to the personal data of its registered users and website visitors in the Philippines.

Our designated Data Protection Officer (DPO) can be contacted at [email protected] for all privacy-related inquiries and data subject requests. We take our obligations under RA 10173 seriously, and our DPO is empowered to respond to all data subject requests within the statutory timeframes.

2 Personal Data We Collect

17jl collects the following categories of personal data from users of the Platform:

2.1 Registration and Identity Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (for age verification — 21+ requirement);
• Philippine mobile number (used as primary account identifier);
• Email address;
• Residential address;
• Gender (optional at registration, required for full KYC).

2.2 Identity Verification (KYC) Data

• Copies or photographs of government-issued photo IDs (e.g., PhilSys National ID, Philippine Passport, Driver's License, SSS Unified ID, UMID, Voter's ID, PRC ID);
• Selfie photographs submitted for liveness verification;
• Tax Identification Number (TIN) where required for large-transaction reporting under PAGCOR and AMLC guidelines.

2.3 Financial and Transaction Data

• GCash account numbers, PayMaya account numbers, or other payment account identifiers linked to your 17jl Account;
• Deposit and withdrawal amounts, dates, and references;
• Bank account details where bank transfers are used;
• Betting and gaming transaction history.

2.4 Technical and Usage Data

• IP address and geolocation data (used for jurisdiction compliance and fraud detection);
• Device identifiers, browser type, and operating system;
• Session logs, login timestamps, and Platform navigation data;
• Game play history and session duration data.

2.5 Communications Data

• Records of your interactions with 17jl customer support (live chat transcripts, email correspondence);
• Feedback and survey responses submitted voluntarily.

2.6 Data Table Summary

3 How We Collect Your Data

17jl collects personal data through the following means:

• Directly from you — when you register an account, complete KYC, make a deposit or withdrawal, contact support, or respond to a survey;
• Automatically — through cookies, session tracking, and our Platform's logging systems when you access or use 17jl.org;
• From payment providers — GCash, PayMaya, and bank payment gateways share transaction confirmation data with 17jl for deposit and withdrawal processing;
• From third-party identity verification services — 17jl may use accredited third-party KYC service providers to assist in verifying the authenticity of submitted identity documents. These providers act as Personal Information Processors under binding data processing agreements;
• From PAGCOR and law enforcement — in limited circumstances, 17jl may receive data from PAGCOR or other Philippine authorities as part of regulatory or legal proceedings.

4 Why We Use Your Personal Data

17jl processes your personal data for the following purposes:

• Account creation and management — to register your account, verify your identity, and maintain your account in operational status;
• Age verification — to ensure all users are 21 years of age or older as required by PAGCOR regulation and Philippine law;
• Service delivery — to enable you to play games, place bets, deposit funds, and make withdrawals on the 17jl Platform;
• Payment processing — to process deposits and withdrawals through your chosen payment method (GCash, PayMaya, bank transfer);
• Regulatory compliance — to comply with PAGCOR reporting requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012;
• Fraud prevention and security — to detect, investigate, and prevent unauthorized access, fraudulent transactions, and prohibited activities;
• Responsible gaming — to monitor gaming patterns and assist in the operation of responsible gaming tools, including deposit limits, self-exclusion, and cooling-off periods;
• Customer support — to respond to your inquiries, complaints, and support requests;
• Platform improvement — to analyze usage patterns (in aggregate, anonymized form) to improve 17jl's services, features, and performance;
• Marketing communications — to send you promotional offers, bonus notifications, and relevant product updates where you have provided consent and not subsequently withdrawn it.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, 17jl processes your personal data on the following legal bases:

• Consent — for marketing communications and the processing of sensitive personal information (identity document images). You may withdraw consent at any time, though withdrawal will not affect prior lawful processing;
• Contractual necessity — processing required to perform our contract with you, including account management, payments processing, and game delivery;
• Legal obligation — processing required to comply with PAGCOR licensing conditions, the AMLA, NPC regulations, and other applicable Philippine law;
• Legitimate interest — processing for fraud detection, security monitoring, and Platform improvement, where our legitimate interests are not overridden by your data protection rights.

6 Data Sharing and Disclosure

17jl does not sell your personal data. We share your personal data only in the following circumstances:

6.1 Service Providers (Personal Information Processors)

17jl engages third-party service providers who process personal data on 17jl's behalf under binding data processing agreements. These include: payment gateway providers (GCash/GXI, PayMaya/Voyager Innovations, bank payment processors); KYC and identity verification service providers; cloud infrastructure providers hosting the 17jl Platform; customer support platform providers; and responsible gaming monitoring service providers.

6.2 Regulatory and Legal Authorities

17jl will disclose personal data to the following authorities when required by law or PAGCOR regulation:

• Philippine Amusement and Gaming Corporation (PAGCOR);
• Anti-Money Laundering Council (AMLC) — for covered and suspicious transaction reports;
• National Privacy Commission (NPC);
• Philippine law enforcement agencies and courts when required by valid legal process.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of 17jl's business or assets, your personal data may be transferred to the successor entity, subject to the same data protection obligations described in this Policy. You will be notified of any such transfer via your registered email address.

7 Data Retention

17jl retains your personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following minimum retention periods imposed by Philippine law and PAGCOR regulation:

• Account data and KYC records: Retained for a minimum of five (5) years after account closure, as required by PAGCOR and AMLA guidelines;
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction, as required by the AMLA and Bureau of Internal Revenue (BIR) regulations;
• Customer support records: Retained for two (2) years after the resolution of the support interaction;
• Marketing consent records: Retained until consent is withdrawn and for three (3) years thereafter as evidence of consent;
• Security and access logs: Retained for twelve (12) months in active storage, then archived for a further twelve (12) months.

Upon expiry of applicable retention periods, personal data is securely destroyed or irreversibly anonymized using industry-standard deletion methods.

8 Security Measures

17jl implements the following technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption: 256-bit SSL/TLS encryption on all data in transit between your device and 17jl's servers. Sensitive stored data (payment details, identity document data) is encrypted at rest using AES-256;
• Access controls: Role-based access controls limit access to personal data to employees and processors who require it for their specific functions. All access is logged and auditable;
• Authentication: Multi-factor authentication (MFA) is required for all 17jl staff accessing systems containing personal data;
• Penetration testing: Regular independent security assessments and penetration tests of the 17jl Platform;
• Incident response: A documented data breach response plan, including mandatory notification to the National Privacy Commission within 72 hours of discovery of a qualifying personal data breach, and notification to affected users where the breach is likely to result in a real risk of serious harm;
• Staff training: All 17jl personnel with access to personal data complete data protection training upon onboarding and annually thereafter.

9 Cookies and Tracking Technologies

17jl uses the following types of cookies and similar tracking technologies on the Platform:

• Strictly necessary cookies: Required for the Platform to function, including session management and login authentication. These cannot be disabled;
• Performance and analytics cookies: Collect anonymized data about how users navigate the Platform to help us improve its performance and usability;
• Functional cookies: Remember your preferences (such as language settings and game display preferences) to enhance your experience;
• Security cookies: Assist in detecting and preventing fraudulent activity, including CSRF protection tokens and device fingerprinting for login security.

17jl does not use third-party advertising cookies or cross-site behavioral tracking cookies. You may control non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the 17jl Platform.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012, as a Philippine data subject you have the following rights in relation to your personal data held by 17jl:

• Right to be informed — to know how 17jl collects and processes your personal data, as described in this Policy;
• Right to access — to request a copy of the personal data 17jl holds about you;
• Right to rectification — to have inaccurate or incomplete personal data corrected;
• Right to erasure ("right to be forgotten") — to request deletion of your personal data in certain circumstances, subject to 17jl's legal retention obligations;
• Right to object — to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to data portability — to receive your personal data in a structured, commonly used, machine-readable format;
• Right to lodge a complaint — to file a complaint with the National Privacy Commission (NPC) if you believe 17jl has violated your data protection rights.

To exercise any of these rights, contact 17jl's Data Protection Officer at [email protected]. We will respond to verified data subject requests within fifteen (15) business days as required by NPC regulations. Some requests may take longer where verification of identity is required or where the request intersects with PAGCOR or AMLA regulatory obligations.

11 Children's Privacy and Underage Users

The 17jl Platform is strictly for persons aged 21 years and older. 17jl does not knowingly collect personal data from any person under the age of 21. The Platform's registration process includes age verification against the date of birth provided, and KYC verification confirms age against a government-issued photo ID before the first withdrawal is processed.

If 17jl becomes aware that personal data has been collected from a person under 21 years of age, the Account will be immediately closed, the personal data deleted (subject to any mandatory regulatory retention), and any deposits returned to the source payment account. PAGCOR will be notified where required by regulation.

Parents or guardians who believe a minor has accessed or registered on 17jl should contact 17jl support immediately at [email protected].

12 Changes to This Privacy Policy

17jl may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When we make material changes, we will:

• Update the "Last Updated" date at the top of this Policy;
• Post a notification on the 17jl Platform for a period of at least 30 days;
• Send a notification to your registered email address or mobile number for significant changes that affect your rights.

Your continued use of 17jl after the effective date of a revised Policy constitutes your acknowledgment of the changes. We encourage you to review this Policy periodically.

13 Contact Us — Data Protection Officer

For all privacy-related inquiries, data subject rights requests, or concerns about 17jl's data practices, contact our Data Protection Officer:

• Email: [email protected] — subject line "Privacy / DPO Request"
• Live Chat: Available 24/7 via the 17jl Platform — ask to be connected to the DPO team
• Response Time: Within 15 business days for formal data subject requests; within 24 hours for general privacy inquiries

If you are not satisfied with 17jl's response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.