52jl Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by 52jl ("52jl," "we," "us," or "our") and applies to all personal data collected from individuals ("you," "your," or "Player") who access or use the 52jl online gaming platform available at 52jl.app, including any mobile-optimized interfaces, customer support channels, and promotional communications (collectively, the "Platform").

52jl is committed to protecting the privacy and security of your personal data. We process personal data in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. Where applicable, we also observe the data protection standards required by PAGCOR as part of our operating obligations.

By registering an account on 52jl, making a deposit, or otherwise using the Platform, 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 with this Policy, please discontinue use of the Platform and contact our support team to request account closure.

2. Personal Data We Collect

52jl collects the following categories of personal data, depending on how you interact with the Platform:

2.1 Identity and Contact Data

Collected during account registration and KYC verification:

2.2 Financial Data

Collected to process deposits, withdrawals, and comply with anti-money laundering obligations:

2.3 Gaming and Behavioral Data

Collected automatically as you use the Platform:

2.4 Technical Data

Collected automatically by our systems when you access the Platform:

2.5 Communications Data

Collected when you contact our support team or respond to promotions:

3. How We Collect Your Data

52jl collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and behavioral data collected automatically through cookies, web beacons, server logs, and similar tracking technologies as you navigate and use the Platform.
• Third-Party Sources: Identity verification data received from KYC service providers; fraud and AML screening data from compliance partners; payment confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors.
• Publicly Available Sources: In limited circumstances, 52jl may supplement your profile with information from publicly available sources for fraud prevention or regulatory compliance purposes.

4. How We Use Your Personal Data

52jl uses your personal data for the following purposes:

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 52jl 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 delivery of gaming services — is carried out on the basis that it is necessary for the performance of that contract.
• Legal Obligation: Processing required to comply with applicable Philippine law, including anti-money laundering obligations under RA 9160 (as amended), PAGCOR reporting requirements, and tax obligations.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where such interests are not overridden by your rights and interests.
• Consent: Processing for direct marketing communications and non-essential cookies, where we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

52jl does not sell your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC and Identity Verification Providers: Third-party identity verification services engaged to assist with KYC compliance and age verification.
• Fraud Prevention and AML Partners: Compliance technology providers engaged to assist with anti-money laundering screening and fraud detection.
• Game Software Providers: Licensed game developers and live dealer studios whose games are made available on the 52jl Platform, to the extent necessary for game delivery and fairness auditing.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulatory directive.
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by 52jl, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of 52jl's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

7. Cookies & Tracking Technologies

52jl uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings, display preferences, and responsible gaming tool configurations.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping us identify areas for improvement. These are only set with your consent.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your gaming activity and preferences. These are only set with your explicit consent and can be withdrawn at any time.

You can manage your cookie preferences through the cookie settings panel available on the Platform. Please note that disabling certain cookies may affect the functionality of some Platform features.

8. Data Security

52jl 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:

• Encryption in Transit: All data transmitted between your device and 52jl servers is encrypted using TLS 1.2 or higher (256-bit SSL encryption).
• Encryption at Rest: Sensitive personal data, including government ID documents and financial account details, is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data is restricted to authorized 52jl personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Secure Infrastructure: 52jl's Platform is hosted on secure, redundant infrastructure with regular security patching, vulnerability scanning, and penetration testing.
• Staff Training: All 52jl personnel who handle personal data receive regular data protection and security awareness training.
• Incident Response: 52jl maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights, we will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

9. Data Retention

52jl 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 relationship with 52jl, plus a minimum of five (5) years following account closure, as required by PAGCOR regulations and anti-money laundering law.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with RA 9160 (Anti-Money Laundering Act) and applicable tax regulations.
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session, for dispute resolution and regulatory audit purposes.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing Preferences: Retained until you withdraw consent or request deletion, whichever is earlier.
• Technical Logs: Retained for up to twelve (12) months for security monitoring and fraud prevention purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with you as an individual.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 52jl. You may exercise any of these rights by contacting our Data Protection Officer using the details in Section 15.

11. Children's Privacy

The 52jl Platform is strictly intended for individuals who are 21 years of age or older. 52jl does not knowingly collect personal data from individuals under the age of 21. The minimum age requirement is a strict legal condition of use, consistent with Philippine gambling regulations.

If 52jl becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on 52jl, please contact our support team immediately so that we can investigate and take appropriate action.

12. Cross-Border Data Transfers

In the course of providing the Platform and its associated services, your personal data may be transferred to and processed in countries outside the Philippines — for example, where our game software providers, cloud infrastructure providers, or KYC service providers are located.

Where such transfers occur, 52jl ensures that appropriate safeguards are in place to protect your personal data, in accordance with the requirements of the Data Privacy Act of 2012 and NPC regulations. These safeguards may include:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law;
• Transfers to countries recognized by the NPC as providing an adequate level of data protection;
• Other legally recognized transfer mechanisms as approved by the National Privacy Commission.

You may request further information about the specific safeguards applicable to any cross-border transfer of your personal data by contacting our Data Protection Officer.

13. Third-Party Links and Services

The 52jl Platform may contain references to third-party services, such as payment processors and game providers. These third parties operate their own privacy policies, which are independent of this Policy. 52jl is not responsible for the privacy practices of third-party services and encourages you to review their respective privacy policies before providing any personal data to them.

52jl does not include external links to unrelated third-party websites within the Platform. Any third-party integrations present on the Platform (such as payment gateways) are subject to contractual data protection obligations with 52jl, as described in Section 6.

14. Changes to This Privacy Policy

52jl 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 date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms.

If you do not agree with any changes to this Policy, you should discontinue use of the Platform and may request account closure by contacting our support team.

15. Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 52jl handles your personal data, please contact our Data Protection Officer using the details below:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.

This Privacy Policy was last reviewed and updated on January 1, 2026. All previous versions of this Privacy Policy are superseded by this document.