23jl Privacy Policy

01 Introduction

This Privacy Policy is issued by 23jl ("we," "us," or "our"), the operator of the online gaming platform accessible at https://23jl.net and its associated mobile applications (collectively, the "Platform"). This Policy applies to all personal data collected from players, visitors, and any other individuals who interact with the 23jl Platform.

23jl is committed to protecting the privacy and personal data of all individuals who use our Platform. We process personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC).

By registering an account on 23jl, accessing the Platform, or using any of our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of the Platform immediately.

02 Personal Data We Collect

23jl collects the following categories of personal data from players and platform users:

We do not collect sensitive personal information such as biometric data, health records, or political affiliations unless specifically required by applicable law or regulatory authority and with your explicit consent.

03 How We Collect Your Data

23jl collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment confirmation data from payment processors such as GCash, PayMaya, BDO, BPI, and Metrobank.
• Regulatory sources: Information received from PAGCOR or other competent Philippine authorities in connection with regulatory compliance obligations.

04 How We Use Your Personal Data

23jl uses the personal data we collect for the following purposes:

• To create, manage, and maintain your 23jl player account.
• To verify your identity and age in compliance with Philippine gaming regulations (21+ requirement).
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP).
• To provide customer support and respond to your inquiries and complaints.
• To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct.
• To comply with our legal and regulatory obligations under Philippine law, including reporting obligations to PAGCOR and other competent authorities.
• To send you transactional communications, including account notifications, deposit confirmations, and withdrawal updates.
• To send you promotional communications about 23jl offers and new games, where you have consented to receive such communications.
• To analyze platform usage and improve the performance, security, and user experience of the 23jl Platform.
• To enforce our Terms & Conditions and other platform policies.

23jl will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

05 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 23jl processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and provision of gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR reporting requirements, and tax obligations.
• Legitimate interests: Processing necessary for 23jl's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — including for marketing communications and certain cookie-based tracking. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Data Sharing & Disclosure

23jl does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BDO, BPI, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Anti-fraud and security providers: Service providers engaged to detect and prevent fraudulent activity, money laundering, and other prohibited conduct on the Platform.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by 23jl, subject to confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of all or part of 23jl's business, your personal data may be transferred to the successor entity, subject to equivalent privacy protections.

All third parties with whom 23jl shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

07 Cookies & Tracking Technologies

23jl uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Performance cookies: Used to collect anonymized data about how players use the Platform, including pages visited and error messages encountered, to help us improve platform performance.
• Functional cookies: Used to remember your preferences and settings, such as language preferences and display options, to provide a more personalized experience.
• Analytics cookies: Used to understand aggregate player behavior and platform usage patterns to inform product development decisions.

You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 23jl Platform. By continuing to use the Platform after being presented with our cookie notice, you consent to our use of cookies as described in this Policy.

08 Data Security

23jl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 23jl Platform.
• AES-256 encryption for sensitive data stored in our systems.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While 23jl takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 23jl will notify you and the NPC in accordance with applicable legal requirements.

09 Data Retention

23jl retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLC and tax record-keeping requirements.
• Communications data: Retained for up to three (3) years from the date of the communication, or longer where required for ongoing dispute resolution or legal proceedings.
• Technical and usage data: Retained for up to two (2) years from collection, unless required for longer periods for security or fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 23jl's data disposal procedures.

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 23jl:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data 23jl holds about you and information about how it is being processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held by 23jl.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 23jl's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: The right to lodge 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, please contact our Data Protection Officer at the details provided in Section 15 of this Policy. 23jl will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11 Children's Privacy

The 23jl Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 23jl does not knowingly collect personal data from individuals under the age of 21.

If 23jl becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the 23jl Platform, please contact our support team immediately so that we can investigate and take appropriate action.

12 International Data Transfers

23jl primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or international KYC verification services.

Where personal data is transferred outside the Philippines, 23jl ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses consistent with NPC requirements. Such transfers are made only to countries or organizations that provide an adequate level of data protection, or where specific safeguards have been implemented.

13 Third-Party Links

The 23jl Platform may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to the 23jl Platform and does not cover the privacy practices of any third-party websites or services. 23jl is not responsible for the privacy practices or content of any third-party sites.

We encourage you to review the privacy policies of any third-party websites you visit. The inclusion of a link on the 23jl Platform does not constitute an endorsement of the linked site or its privacy practices.

14 Updates to This Privacy Policy

23jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, we will provide reasonable advance notice to registered players via email or a prominent notice on the Platform.

The current version of this Privacy Policy, together with its effective date, is always available on this page. We recommend that you review this Policy periodically. Your continued use of the 23jl Platform following the effective date of any update constitutes your acceptance of the revised Policy.

15 Contact & Data Protection Officer

23jl has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data privacy laws. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our DPO:

Data Protection Officer — 23jl
Email: [email protected]

For general support inquiries, you may also reach our customer support team at: [email protected]

If you are not satisfied with our response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy was last updated on January 1, 2026. 23jl reserves the right to update this Policy at any time. Continued use of the Platform constitutes acceptance of the current Policy.