37ji Casino Privacy Policy

1.1 This Privacy Policy ("Policy") applies to all personal data processed by 37ji in connection with the operation of the 37ji online gaming platform at 37ji.org. It applies to all registered players, visitors, and any other persons whose personal data is processed by 37ji in connection with the Platform.

1.2 For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to names, email addresses, mobile numbers, IP addresses, device identifiers, and payment data.
• "Processing" means any operation performed on personal data, including collection, recording, storage, retrieval, use, transmission, restriction, erasure, or destruction.
• "Data Subject" means the natural person to whom the personal data relates — in most cases, you, the 37ji player or visitor.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — 37ji.
• "DPA" means the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

1.3 This Policy should be read alongside the 37ji Terms & Conditions, which are incorporated herein by reference and available at 37ji.org/terms-conditions.

2.1 The data controller responsible for personal data collected through the 37ji Platform is the operating entity of 37ji.org. All data requests, privacy inquiries, and complaints regarding the processing of personal data by 37ji should be directed to the 37ji Data Privacy team at [email protected].

2.2 37ji is committed to processing all personal data in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC) of the Philippines.

3.1 37ji collects the following categories of personal data, limited to what is necessary for the stated purposes:

3.2 37ji does not collect sensitive personal information — such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data — unless expressly required for KYC purposes under regulatory mandate, in which case such data is processed under strict additional safeguards.

37ji collects personal data through the following channels:

• Direct provision: Data you provide when registering an account, completing KYC verification, submitting a deposit or withdrawal, contacting support, or participating in a promotion at 37ji.
• Automated collection: Technical data collected automatically through your browser or device when you access 37ji.org, including via cookies, session tokens, and server logs. See Section 6 for our full cookie policy.
• Transaction records: Data generated by your gaming and payment activity on the Platform, including bet records, game results, and payment processor confirmations.
• Third-party providers: Where permitted, identity verification data from KYC service providers; fraud scoring data from anti-fraud platforms; and payment confirmation data from GCash, Maya, BPI, BDO, and other integrated payment processors.
• Publicly available sources: Limited use of publicly available data to verify identity information provided during KYC, in accordance with applicable Philippine law.

5.1 37ji processes personal data only where a lawful basis for processing exists under the Philippine DPA. The following table sets out the primary purposes for which 37ji processes personal data and the corresponding legal basis:

6.1 37ji uses cookies and similar tracking technologies on the Platform. Cookies are small data files placed on your device by your browser when you visit 37ji.org. They serve the following purposes:

• Strictly Necessary Cookies: Required for basic Platform functionality, including maintaining your login session, processing transactions, and applying security measures. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences (e.g., language, game lobby filter settings) to improve your experience at 37ji.
• Analytics Cookies: Used internally to understand how players interact with the 37ji Platform, which pages are most visited, and where usability improvements can be made. No individual player is identified in analytics reports.
• Security Cookies: Support 37ji's fraud detection and account protection systems by tracking session behavior patterns.

6.2 You may control non-essential cookies through your browser settings. Disabling cookies may impair the functionality of certain features of the 37ji Platform. Strictly necessary cookies operate without the option to disable, as they are essential for the secure provision of the gaming service.

7.1 37ji does not sell, rent, or trade your personal data to third parties. 37ji may share personal data with third parties only in the following circumstances, and only to the extent strictly necessary:

• Game providers and studio partners (e.g., PG Soft, Pragmatic Play, Evolution Gaming, JILI) — limited to the data necessary to facilitate game sessions and resolve game disputes. Game providers are bound by data processing agreements with 37ji.
• Payment processors (GCash, Maya, BPI, BDO, Metrobank, and other integrated processors) — limited to transaction data required to process deposits and withdrawals. Payment processors operate under their own applicable privacy frameworks.
• KYC and identity verification providers — limited to identity data required to complete verification under applicable regulatory requirements.
• Fraud prevention and cybersecurity services — limited to technical and behavioral data necessary for account security and fraud detection.
• Regulatory and law enforcement authorities — where 37ji is required by law, court order, or regulatory directive to disclose personal data, including disclosures to PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC) of the Philippines.
• Professional advisors — lawyers, auditors, and accountants advising 37ji, subject to confidentiality obligations.

7.2 In the event of a corporate restructuring, merger, acquisition, or sale of all or substantially all of 37ji's assets, personal data may be transferred as part of that transaction. Affected players will be notified in advance via their registered email address, and data will continue to be processed in accordance with this Policy.

8.1 37ji retains personal data for the periods set out below, after which data is securely deleted or anonymized unless a longer retention period is required by applicable law:

8.2 Where 37ji is required by law to retain data beyond the periods above, data will be retained for the legally mandated period and then securely deleted.

9.1 37ji implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Key security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 37ji's servers;
• AES-256 encryption at rest for sensitive data stored in 37ji's databases;
• Password hashing using industry-standard one-way hashing algorithms — 37ji does not store plaintext passwords;
• Two-factor authentication available to all players and required for all 37ji administrative staff accounts;
• Regular security audits and penetration testing of the Platform infrastructure;
• Access controls limiting employee access to personal data to those who require it for their specific role;
• Incident response procedures in place for the detection, reporting, and remediation of any personal data breach.

9.2 Data Breach Notification. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 37ji will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay. Notifications will be sent to your registered email address.

9.3 While 37ji employs robust security measures, no internet-based platform can guarantee absolute data security. You are responsible for maintaining the security of your 37ji login credentials, particularly by using a strong and unique password and enabling two-factor authentication.

10.1 Under the Philippine Data Privacy Act of 2012 and its Implementing Rules, you have the following rights in respect of your personal data held by 37ji. All rights may be exercised by contacting [email protected] with a verified request. 37ji will respond within 30 calendar days.

11.1 The 37ji Platform is strictly intended for persons aged 21 years and above. 37ji does not knowingly collect personal data from persons under the age of 21. Any account found to have been registered by a person under 21 will be immediately closed and all associated personal data will be deleted from 37ji's systems, except to the extent retention is required by applicable law to document the age violation.

11.2 If you are a parent or guardian and believe that a minor has registered an account or provided personal data to 37ji, please contact [email protected] immediately. 37ji will take prompt action to investigate and, where confirmed, close the account and delete the relevant data.

12.1 37ji sends marketing communications (including promotional offers, bonus alerts, new game announcements, and seasonal campaigns) only to players who have given explicit opt-in consent during registration or at a subsequent point through their Account Settings.

12.2 You may withdraw your consent to marketing communications at any time by: (a) using the unsubscribe link included in every marketing email from 37ji; (b) adjusting your communication preferences in your 37ji Account Settings; or (c) contacting [email protected] with an explicit unsubscribe request.

12.3 Withdrawal of marketing consent takes effect within 5 business days. Transactional communications (deposit confirmations, withdrawal notifications, security alerts, and account notices) are not marketing communications and will continue to be sent regardless of marketing opt-out status, as they are necessary for the operation of your 37ji account.

12.4 37ji will not send marketing communications to players who are on self-exclusion during their exclusion period. Self-exclusion automatically suppresses all marketing communications at 37ji.

13.1 Some of 37ji's service providers and game studio partners are located outside the Philippines. Where personal data is transferred to recipients in other jurisdictions, 37ji ensures that appropriate safeguards are in place to protect the data in accordance with the Philippine DPA and NPC regulations on cross-border data transfers.

13.2 Appropriate safeguards for cross-border transfers at 37ji include: contractual data processing agreements incorporating NPC-approved standard contractual clauses; transfer to jurisdictions with equivalent data protection standards; and binding corporate rules where applicable within the 37ji group.

13.3 You may request information about the specific safeguards in place for any particular cross-border transfer by contacting [email protected].

14.1 If you have concerns about how 37ji processes your personal data, you are encouraged to first raise the issue directly with 37ji by contacting [email protected] with the subject line "DATA PRIVACY COMPLAINT". 37ji will acknowledge your complaint within 48 hours and investigate it within 30 calendar days.

14.2 If you are not satisfied with 37ji's response to your data privacy complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

15.1 37ji reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or 37ji's data processing practices. The "Last Reviewed" date at the top of this Policy will be updated whenever a revision is made.

15.2 Material changes to this Policy — those that significantly affect your rights or how your data is processed — will be communicated to registered players via email to their registered address at least 7 days before the changes take effect.

15.3 Your continued use of the 37ji Platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of, and agreement to, the revised Policy. If you do not agree with a material change, you may close your 37ji account in accordance with the account closure procedure in the Terms & Conditions.