37ji Casino Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by 37ji Casino ("37ji," "we," "us," or "our") through our website (37ji.cam), mobile-optimized platforms, customer support channels, and any associated services. By creating an account with 37ji, depositing funds, or using our gaming services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal data as described herein.

37ji operates in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable Philippine data protection laws. We are committed to protecting your personal information and maintaining the highest standards of data security and privacy.

2. Data Controller

37ji is the data controller responsible for the collection, processing, and storage of your personal data. As the data controller, we determine the purposes and means of processing your personal information and are accountable for ensuring that all data processing activities comply with applicable privacy laws.

For any questions, concerns, or requests regarding your personal data or this Privacy Policy, you may contact our Data Protection Officer at:

• Email: [email protected]
• Subject Line: "Data Privacy Inquiry" or "Data Protection Request"
• Response Time: We aim to respond to all privacy-related inquiries within seven (7) business days.

3. Personal Data We Collect

37ji collects various categories of personal data necessary to provide our gaming services, comply with legal and regulatory obligations, and improve user experience. The personal data we collect includes but is not limited to:

3.1 Information You Provide Directly

• Account Registration Information: Full legal name, date of birth, gender, residential address, email address, mobile telephone number, and username.
• Identity Verification Documents: Government-issued photo identification (Philippine passport, driver's license, UMID, Postal ID, voter's ID), selfie verification photos, and proof of address documents (utility bills, bank statements).
• Financial Information: Payment method details including GCash account information, Maya wallet details, bank account numbers, cryptocurrency wallet addresses, and transaction history.
• Communication Data: Correspondence with customer support, chat logs, email communications, and feedback submissions.
• Marketing Preferences: Communication preferences, newsletter subscriptions, and promotional opt-in/opt-out choices.

3.2 Information Collected Automatically

• Device Information: Device type, operating system, browser type and version, unique device identifiers, mobile network information, and screen resolution.
• Usage Data: Pages visited, games played, bet history, deposit and withdrawal records, login times, session duration, and clickstream data.
• Location Data: IP address, geolocation data derived from IP address or device GPS (where permitted), and time zone information.
• Cookies and Tracking Technologies: Data collected through cookies, web beacons, pixel tags, and similar technologies as described in our Cookie Policy.

3.3 Information from Third Parties

• Payment Processors: Transaction verification data from GCash, Maya, banks, and other payment providers.
• Identity Verification Services: Verification results from third-party KYC providers used to authenticate your identity and age.
• Fraud Prevention Services: Fraud risk assessments and behavioral analytics from third-party security providers.

4. How We Use Your Personal Data

37ji processes your personal data for the following lawful purposes:

4.1 Service Provision and Account Management

• Create and manage your 37ji account.
• Process deposits, withdrawals, and gaming transactions.
• Provide access to games, sports betting, live casino, bingo, and fishing game services.
• Authenticate your identity and verify your eligibility to use our services.
• Maintain gaming history, transaction records, and account balances.
• Provide customer support and respond to inquiries.

4.2 Legal and Regulatory Compliance

• Comply with Know Your Customer (KYC) and anti-money laundering (AML) requirements under Philippine law and PAGCOR regulations.
• Verify age to ensure compliance with the legal gambling age requirement (21+).
• Detect and prevent fraud, money laundering, and other illegal activities.
• Respond to legal requests from law enforcement, regulatory authorities, or courts.
• Maintain records required by Philippine gaming regulations and tax authorities.

4.3 Security and Fraud Prevention

• Monitor account activity for suspicious or fraudulent behavior.
• Implement security measures to protect your account and personal data.
• Investigate and resolve disputes, violations of our Terms & Conditions, or suspected abuse.
• Maintain audit logs for security and compliance purposes.

4.4 Marketing and Communication

• Send promotional emails, SMS messages, and push notifications about bonuses, tournaments, and special offers (only with your consent).
• Personalize marketing content based on your gaming preferences and activity.
• Conduct surveys and request feedback to improve our services.
• Send transactional communications such as deposit confirmations, withdrawal notifications, and account updates.

4.5 Service Improvement and Analytics

• Analyze usage patterns to improve website performance, user experience, and game offerings.
• Conduct market research and statistical analysis to understand player preferences.
• Test new features, games, and services before full deployment.
• Optimize platform performance for different devices and internet connection speeds.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 and Philippine data protection law, 37ji processes your personal data based on the following legal grounds:

• Consent: You have provided explicit consent for specific processing activities, such as receiving marketing communications.
• Contractual Necessity: Processing is necessary to perform our contractual obligations under the Terms & Conditions you agreed to when registering for 37ji services.
• Legal Obligation: Processing is required to comply with Philippine laws, regulations, court orders, or instructions from regulatory authorities such as PAGCOR.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, and service improvement, provided these interests do not override your fundamental rights and freedoms.

6. Data Sharing and Disclosure

37ji does not sell, rent, or trade your personal data to third parties for their marketing purposes. However, we may share your personal data with the following categories of recipients under strict confidentiality obligations:

6.1 Service Providers and Business Partners

• Payment Processors: GCash, Maya, banks, cryptocurrency networks, and other payment providers that facilitate deposits and withdrawals.
• Game Providers: Software providers such as Pragmatic Play, Evolution Gaming, PG Soft, and NetEnt that supply gaming content on the 37ji platform.
• Identity Verification Services: Third-party KYC providers that verify your identity, age, and address.
• Fraud Prevention and Security Services: Third-party vendors that provide fraud detection, risk assessment, and cybersecurity services.
• Cloud Hosting and IT Infrastructure: Cloud service providers that host our servers and databases.
• Customer Support Tools: Third-party platforms used to manage customer inquiries and support tickets.

6.2 Regulatory and Legal Authorities

• PAGCOR: Philippine Amusement and Gaming Corporation and other Philippine gaming regulatory bodies as required by law.
• Law Enforcement: Philippine National Police, National Bureau of Investigation, and other law enforcement agencies pursuant to valid legal requests.
• Tax Authorities: Bureau of Internal Revenue (BIR) and other Philippine tax authorities as required by tax laws.
• Courts and Legal Proceedings: Courts, arbitrators, and legal counsel in connection with legal disputes or proceedings.

6.3 Corporate Transactions

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal data may be transferred to a successor entity as part of the transaction. We will notify you via email or prominent notice on our website before your data is transferred and becomes subject to a different Privacy Policy.

7. Data Retention

37ji retains your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal and regulatory obligations, and resolve disputes. Specific retention periods include:

• Active Accounts: Personal data is retained for the duration of your active account plus the retention periods below after account closure.
• Transaction Records: Financial transaction data is retained for a minimum of five (5) years after the transaction date to comply with anti-money laundering regulations and tax laws.
• KYC Documents: Identity verification documents are retained for five (5) years after account closure to comply with PAGCOR requirements.
• Gaming History: Bet history and game logs are retained for five (5) years to support dispute resolution and regulatory audits.
• Marketing Data: Marketing preferences and communication history are retained until you withdraw consent or for two (2) years after your last interaction with marketing communications.
• Legal Holds: Data subject to legal holds, ongoing disputes, or regulatory investigations is retained until the matter is resolved, even if it exceeds standard retention periods.

After the applicable retention period expires, your personal data will be securely deleted or anonymized such that it can no longer be associated with you.

8. Data Security

37ji implements industry-standard technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption, the same standard used by financial institutions.
• Secure Storage: Personal data is stored on secure servers with restricted access, firewalls, and intrusion detection systems.
• Access Controls: Personal data is accessible only to authorized 37ji employees and service providers who require access to perform their duties and are bound by confidentiality obligations.
• Two-Factor Authentication: Optional two-factor authentication is available to add an extra layer of security to your account.
• Regular Security Audits: We conduct regular security assessments, vulnerability scans, and penetration testing to identify and address potential security risks.
• Incident Response: We maintain an incident response plan to promptly detect, investigate, and respond to data breaches or security incidents.

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. You also have a responsibility to protect your account by choosing a strong password, keeping your login credentials confidential, and logging out after each session on shared devices.

9. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal data:

• Right to Information: You have the right to be informed about how your personal data is collected, used, and shared.
• Right to Access: You have the right to request access to your personal data and obtain a copy of the data we hold about you.
• Right to Correction: You have the right to request correction of inaccurate or incomplete personal data.
• Right to Erasure (Right to be Forgotten): You have the right to request deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another data controller.
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes or processing based on legitimate interests.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Rights Request." We will respond to your request within fifteen (15) business days. Please note that certain requests may be subject to verification of your identity and may be limited by legal obligations to retain certain data.

10. Cookies and Tracking Technologies

37ji uses cookies and similar tracking technologies to enhance user experience, analyze website traffic, and deliver personalized content. Cookies are small text files stored on your device when you visit our website. We use the following types of cookies:

• Essential Cookies: Necessary for the website to function properly, including authentication, security, and session management.
• Performance Cookies: Collect information about how you use our website to help us improve performance and user experience.
• Functionality Cookies: Remember your preferences and settings to provide a more personalized experience.
• Marketing Cookies: Track your browsing activity to deliver relevant advertisements and measure the effectiveness of marketing campaigns.

You can manage cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of the 37ji website and limit your access to certain features.

11. International Data Transfers

37ji primarily operates within the Philippines and stores personal data on servers located in the Philippines or in secure cloud data centers in jurisdictions with adequate data protection standards. In certain cases, your personal data may be transferred to service providers located outside the Philippines for purposes such as cloud hosting, payment processing, or fraud prevention.

When we transfer personal data internationally, we ensure that appropriate safeguards are in place, such as standard contractual clauses, data processing agreements, or transfers to jurisdictions recognized by the Philippine National Privacy Commission as providing adequate data protection. By using 37ji services, you consent to the transfer of your personal data to these jurisdictions under the protections described in this Privacy Policy.

12. Children's Privacy

37ji services are strictly intended for individuals aged 21 years and above in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete such data and close the associated account.

Parents and guardians who believe their child has provided personal data to 37ji should contact us immediately at [email protected] so we can take appropriate action.

13. Changes to This Privacy Policy

37ji reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. When we make changes, we will update the "Last Updated" date at the top of this Privacy Policy and post the revised version on our website.

For material changes that significantly affect your rights or how we process your personal data, we will provide additional notice via email or prominent notification on the 37ji website. Your continued use of 37ji services after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

• Email: [email protected]
• Subject Line: "Privacy Policy Inquiry"
• Response Time: We aim to respond to all inquiries within seven (7) business days.

You also have the right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe your data privacy rights have been violated. For more information about your rights or to file a complaint, visit the NPC website or contact:

• National Privacy Commission
• 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City, Metro Manila 1308
• Email: [email protected]
• Hotline: (02) 8234-2228