19jl Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 19jl ("we", "us", "our") processes personal data in connection with the 19jl online gaming platform accessible at 19jl.one ("Platform"). It applies to all persons who register, access, or use the Platform, including visitors, registered members, and persons who interact with 19jl's customer support channels.

19jl is a PAGCOR-regulated online gaming operator serving Filipino players across the Philippines. As both a regulated gaming operator and a personal information controller under Philippine law, 19jl is committed to responsible, transparent, and lawful data processing practices that respect the privacy rights of every 19jl member.

This Policy should be read alongside the 19jl Terms & Conditions and any supplementary privacy notices that may be displayed at specific data collection points on the Platform. In the event of any conflict between this Policy and a supplementary notice, the supplementary notice shall prevail with respect to the specific processing activity it describes.

2. Who We Are — Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, 19jl is the personal information controller responsible for personal data collected through the Platform.

19jl operates under a PAGCOR license and processes personal data in compliance with PAGCOR's anti-money laundering and Know Your Customer (KYC) requirements, as well as the data privacy obligations imposed by the National Privacy Commission of the Philippines.

All data collected through the Platform is stored on secure servers. Where data processing is performed by third-party service providers on 19jl's behalf, those providers are contractually bound to process data only according to 19jl's instructions and in compliance with applicable Philippine data privacy law.

3. Personal Data We Collect

3.1 Data You Provide Directly

19jl collects the following categories of personal data that you provide directly during registration, KYC verification, transactions, and support interactions:

3.2 Data Collected Automatically

When you access the 19jl Platform, certain technical data is collected automatically through cookies, log files, and similar technologies:

• IP address and approximate geographic location (province/city level).
• Device type, operating system, browser type and version.
• Pages visited, game sessions initiated, session duration, and navigation paths.
• Referring URL and exit URL.
• Mobile network operator (Globe, Smart, DITO, etc.) where applicable.

3.3 Data from Third Parties

19jl may receive personal data from third-party KYC verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud detection services, and game content providers where such data is necessary to provide Platform services or satisfy regulatory obligations.

4. How 19jl Uses Your Personal Data

19jl uses personal data for the following purposes:

• Account registration and management: Creating and maintaining your 19jl account, verifying your identity, and managing account settings.
• KYC and regulatory compliance: Meeting PAGCOR licensing requirements, anti-money laundering (AML) obligations, and the requirements of Philippine financial regulators.
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers.
• Game provision and personalisation: Delivering game content, tracking game history, calculating winnings, and personalising your game lobby based on play preferences.
• Bonus and promotional administration: Determining eligibility for promotions, tracking wagering requirements, and distributing bonus credits.
• Responsible gaming: Monitoring for problem gambling indicators, applying self-imposed limits, and implementing self-exclusion requests.
• Fraud prevention and security: Detecting and preventing fraudulent transactions, account takeovers, and prohibited activities as defined in the 19jl Terms & Conditions.
• Customer support: Responding to queries, resolving disputes, and providing technical assistance.
• Platform improvement: Analysing usage patterns to improve Platform performance, mobile experience, and game selection.
• Marketing communications: Sending promotional offers and platform updates to members who have opted in to receive such communications. You may opt out at any time via your account notification settings.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173), 19jl processes personal data on the following legal grounds:

• Contractual necessity: Processing required to fulfil our contractual obligations to you under the 19jl Terms & Conditions — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AML laws, tax reporting obligations, and other applicable Philippine regulations.
• Legitimate interests: Processing necessary for 19jl's legitimate interests in preventing fraud, ensuring platform security, and improving our services, provided such interests are not overridden by your data privacy rights.
• Consent: Processing for marketing communications and optional personalisation features where you have provided explicit, freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

19jl does not sell your personal data to third parties. We share personal data only in the following circumstances:

• PAGCOR and regulatory authorities: As required under 19jl's operating license and applicable Philippine law, including mandatory reporting of suspicious transactions to the Anti-Money Laundering Council (AMLC).
• Payment service providers: GCash (GXI), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank receive the transaction data necessary to process deposits and withdrawals.
• KYC and identity verification providers: Third-party KYC platforms process identity documents and biometric data strictly for verification purposes under binding data processing agreements.
• Game content providers: Game providers receive anonymised or pseudonymised session data necessary for game delivery and RNG integrity verification. Providers are contractually prohibited from using this data for independent purposes.
• Legal and law enforcement: Where required by valid court order, subpoena, or applicable Philippine law, or where necessary to protect the safety of 19jl members or the public.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of 19jl's assets, personal data may be transferred as part of that transaction, subject to the same privacy protections described in this Policy.

7. International Data Transfers

Certain 19jl service providers, including game content platforms and cloud infrastructure providers, may process data outside the Philippines. Where such international transfers occur, 19jl ensures that appropriate safeguards are in place in accordance with Section 21 of the Philippine Data Privacy Act, including the use of contractual clauses that impose data protection standards equivalent to those applicable in the Philippines.

Financial transaction data relating to GCash and PayMaya deposits and withdrawals is processed within the Philippines by the respective payment service providers and is subject to their own privacy policies and Bangko Sentral ng Pilipinas (BSP) regulations.

8. Data Retention

19jl retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods mandated by applicable regulations:

• KYC and identity documents: Minimum five (5) years from account closure, as required by PAGCOR and AMLC regulations.
• Financial transaction records: Minimum five (5) years from the date of each transaction.
• Game history and betting records: Minimum three (3) years from the date of each game session.
• Customer support records: Three (3) years from the date of the last interaction.
• Marketing preferences: Until you withdraw consent or close your account, whichever is earlier.

After the applicable retention period, personal data is securely deleted or anonymised in accordance with 19jl's data disposal procedures. Data that has been anonymised and can no longer be attributed to any individual may be retained indefinitely for statistical and analytical purposes.

9. Cookies & Tracking Technologies

19jl uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Required for Platform functionality including maintaining your logged-in session, remembering security preferences, and preventing fraudulent activity. These cannot be disabled without impairing Platform functionality.
• Performance cookies: Collect anonymised usage data (pages visited, load times, error events) to help 19jl improve Platform performance. Data is aggregated and not linked to individual users.
• Functional cookies: Remember your preferences such as language settings, game lobby layout, and responsible gaming limits.
• Analytics cookies: Used by 19jl to understand how Filipino players navigate the Platform and which features are most used. Analytics data is processed in aggregate form.

You may manage cookie preferences through your browser settings. Disabling certain cookies may affect the availability of some Platform features. 19jl does not use third-party advertising cookies or cross-site tracking cookies.

10. Your Data Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), 19jl members have the following rights with respect to their personal data:

• Right to be informed: The right to receive clear information about how your personal data is collected and used — which this Policy provides.
• Right of access: The right to request a copy of the personal data 19jl holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to 19jl's legal obligations to retain certain data under PAGCOR and AML regulations.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting prior processing.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact 19jl's Data Protection Officer via the support email address displayed in the footer of this page. 19jl will respond to all rights requests within fifteen (15) business days, as required by the NPC's implementing rules.

11. Data Security Measures

19jl implements technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL 256-bit encryption for all data in transit between your device and 19jl servers.
• Encryption of sensitive data at rest, including identity documents and financial account references.
• Access controls limiting employee access to personal data on a strict need-to-know basis.
• Multi-factor authentication requirements for all 19jl staff with access to production systems.
• Regular penetration testing and vulnerability assessments conducted by independent security professionals.
• Incident response procedures aligned with NPC breach notification requirements — including mandatory reporting within 72 hours for high-risk breaches.

12. Children's Privacy — 21+ Platform

19jl does not knowingly collect, use, or disclose personal data from minors. All 19jl account registrations require age verification and KYC documentation confirming the member is at least 21 years of age. If 19jl discovers that personal data has been collected from a person under 21, the account will be immediately suspended, the personal data will be deleted, and any associated funds will be handled in accordance with applicable PAGCOR regulations.

If you believe that a minor has registered on the 19jl Platform, please contact 19jl support immediately via the live chat function or the email address in the footer of this page.

13. Changes to This Privacy Policy

19jl reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Material changes will be communicated to registered members via in-Platform notifications or by email to the address on file, with at least fourteen (14) days' advance notice where reasonably practicable.

Your continued use of the 19jl Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. The date of the most recent revision is always displayed at the top of this document. If you do not agree to the amended Policy, you may request account closure as described in the 19jl Terms & Conditions.

14. Contact & Complaints

For questions, concerns, or to exercise your data rights under the Philippine Data Privacy Act, please contact the 19jl Data Protection Officer. Contact details are available via the live chat support function on the Platform and via the email address displayed in the footer of every page on this site.

If you believe that 19jl has not handled your personal data in accordance with this Policy or the Philippine Data Privacy Act, you have the right to file a complaint directly with the National Privacy Commission of the Philippines. Information on the NPC complaint process is available through the NPC's official channels.