54jl Privacy Policy

1. Introduction

54jl ("we," "us," "our") operates the online casino and sports betting platform accessible at 54jl.org, serving Filipino players across the Philippines. As a PAGCOR-licensed operator, 54jl is legally required to collect and process certain categories of personal data as a condition of its licensing obligations, including for identity verification, age confirmation, and anti-money laundering compliance.

54jl takes the privacy of its players seriously. This Privacy Policy explains in plain language exactly what personal data we collect from you, the legal basis on which we process it, what we do with it, who has access to it, and how long we keep it. We also explain the rights available to you under the Data Privacy Act of 2012 and how to exercise them.

This policy applies to all players registered on 54jl regardless of location, though it is primarily designed to address the rights and protections applicable to players in the Philippines.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173), 54jl is the personal information controller in respect of all personal data collected through the 54jl platform. Decisions regarding the purposes and means of processing your personal data are made by 54jl.

54jl has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with the Data Privacy Act and this policy. Contact details for the DPO are provided in Section 16 of this policy.

3. Categories of Personal Data We Collect

54jl collects the following categories of personal data in connection with your use of the platform:

4. How We Collect Your Data

54jl collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey;
• Automatically — through cookies, web beacons, and server logs as you use the 54jl platform, including your IP address, device information, and browsing behaviour within the platform;
• From payment processors — when you transact via GCash, Maya, or bank transfer, payment confirmation data is transmitted to 54jl to verify and record the transaction;
• From identity verification services — 54jl may use third-party KYC service providers to validate the authenticity of identity documents submitted during the verification process;
• From PAGCOR and regulatory bodies — 54jl may receive information from PAGCOR or other Philippine regulatory authorities in connection with licensing compliance and player protection obligations.

5. How We Use Your Personal Data

54jl uses your personal data for the following purposes:

• To create, manage, verify, and maintain your 54jl account;
• To verify your identity and age as required by PAGCOR and the Data Privacy Act;
• To process deposits and withdrawals through your chosen payment method;
• To deliver and operate all games, sports betting markets, and other services on the 54jl platform;
• To monitor gaming activity for responsible gaming purposes, including identifying potential problem gambling behaviour;
• To comply with anti-money laundering (AML) obligations under the Anti-Money Laundering Act (AMLA) and PAGCOR requirements;
• To detect, investigate, and prevent fraud, cheating, collusion, and other prohibited conduct;
• To send account-related communications including transaction confirmations, security alerts, and platform notifications;
• To send marketing communications where you have provided explicit consent and in accordance with your stated marketing preferences;
• To resolve disputes, respond to support queries, and handle complaints;
• To improve the platform through analytics and user research, using anonymised or aggregated data wherever possible.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, 54jl processes your personal data on the following legal bases:

• Performance of a Contract — Processing necessary to fulfil the Terms & Conditions agreement between you and 54jl, including account management, game delivery, and payment processing;
• Legal Obligation — Processing required to comply with applicable Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act itself;
• Legitimate Interests — Processing for fraud detection, security monitoring, and platform analytics, where these interests are not overridden by your fundamental rights and freedoms;
• Consent — Processing for marketing communications and non-essential cookies, where your explicit consent has been obtained. You may withdraw consent at any time without affecting prior lawful processing.

7. Data Sharing & Disclosure

7.1 Service Providers

54jl shares personal data with trusted third-party service providers who process data on our behalf under strict data processing agreements. These include game software providers, payment processors (GCash, Maya, bank partners), KYC verification services, cloud hosting providers, and customer support platform operators. All service providers are contractually bound to process data only for specified purposes and to maintain appropriate security standards.

7.2 Regulatory & Legal Disclosure

54jl will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and courts as required by Philippine law. Such disclosures are made only to the extent necessary and proportionate to the legal obligation or authority in question.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 54jl's business, personal data held by 54jl may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer that materially affects the processing of your personal data.

7.4 No Sale of Data

54jl does not sell, rent, lease, or otherwise trade your personal data to any third party for commercial or marketing purposes. Your data is yours.

8. International Data Transfers

Some of 54jl's service providers — particularly game software providers and cloud infrastructure operators — may be located outside the Philippines. Where personal data is transferred to a recipient in another country, 54jl ensures that appropriate safeguards are in place as required by the Data Privacy Act and the National Privacy Commission's guidelines on cross-border data transfers.

Such safeguards include contractual clauses that bind the receiving party to data protection standards equivalent to those required under Philippine law, and, where available, transfers to jurisdictions recognised as having adequate data protection frameworks.

9. Data Retention

54jl retains personal data for no longer than is necessary for the purposes for which it was collected, subject to any minimum retention periods required by law. The following general retention periods apply:

• Account data and gaming history: Retained for the duration of your account and for five (5) years following account closure, as required by PAGCOR and AMLC regulations;
• KYC documents: Retained for five (5) years from the date of submission or from the date of account closure, whichever is later;
• Financial transaction records: Retained for five (5) years as required by the AMLA and PAGCOR;
• Customer support records: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained for the duration of your consent and for two (2) years following withdrawal of consent.

After the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of individual identities.

10. Security Measures

54jl implements technical and organisational measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 54jl's servers;
• Encryption of stored sensitive data including identity documents and financial account references;
• Role-based access controls ensuring that 54jl staff can only access personal data to the extent required for their specific job function;
• Multi-factor authentication for all internal 54jl systems that process player personal data;
• Regular penetration testing and security audits of the platform and its infrastructure;
• Incident response procedures for detecting, containing, and notifying the National Privacy Commission and affected players of any personal data breach within 72 hours of discovery, as required by the Data Privacy Act.

11. Cookies & Tracking Technologies

54jl uses cookies and similar technologies (including web beacons and local storage) on the 54jl platform. Cookies are small text files placed on your device that help the platform function correctly and improve your experience.

11.1 Essential Cookies

These cookies are strictly necessary for the 54jl platform to function. They manage your login session, maintain wallet balance display, and ensure security features operate correctly. Essential cookies cannot be disabled without preventing you from using the platform.

11.2 Analytical Cookies

54jl uses anonymised analytical cookies to understand how players use the platform — which games are most popular, where players encounter errors, and how navigation flows through the site. This data is used exclusively to improve the platform and is never used to identify individual players.

11.3 Preference Cookies

These cookies remember your platform preferences such as display language, chosen payment method, and notification settings, so you don't need to reconfigure them on every visit.

11.4 Managing Cookies

You can manage and disable non-essential cookies through your browser's settings. Disabling analytical and preference cookies will not prevent you from using 54jl but may affect the quality of your experience. Disabling essential cookies will prevent access to the platform.

12. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 54jl:

• Right to Be Informed — You have the right to know what personal data 54jl holds about you and how it is being used, as set out in this policy;
• Right to Access — You may request a copy of the personal data 54jl holds about you at any time. 54jl will respond to access requests within 30 days;
• Right to Correction — You may request correction of any inaccurate or incomplete personal data. For account details, most corrections can be made directly in your 54jl account settings;
• Right to Erasure — You may request deletion of your personal data where processing is no longer necessary. Note that 54jl may be required to retain certain data for the minimum periods required by PAGCOR and AMLA, overriding erasure requests in those specific categories;
• Right to Object — You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests;
• Right to Data Portability — You may request your personal data in a structured, machine-readable format to transfer to another service where technically feasible;
• Right to Lodge a Complaint — If you believe 54jl has violated your data privacy rights, you may file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, contact 54jl's Data Protection Officer using the details in Section 16. Requests will be responded to within 30 calendar days.

13. Children & Minors

Parents and guardians who believe a minor may have created a 54jl account should contact the support team immediately at support@54jl.org. 54jl will investigate and take appropriate action as a matter of priority.

14. Third-Party Links

The 54jl platform does not contain links to external third-party websites. However, where third-party game software is launched within the 54jl platform, that software is provided by licensed game studios whose own data processing practices are governed by their respective privacy policies. 54jl is not responsible for the privacy practices of third-party game providers, though all providers are contractually required to meet standards consistent with 54jl's data protection obligations.

15. Changes to This Privacy Policy

54jl may update this Privacy Policy from time to time to reflect changes in our data processing practices, new legal requirements, or platform updates. Where changes are material, 54jl will notify registered players via email and/or an in-platform notification at least seven (7) days before the updated policy takes effect.

The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of 54jl following the effective date of any revised policy constitutes your acceptance of the changes. If you do not accept the revised policy, you must discontinue use of the platform and may request account closure.

16. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact 54jl's Data Protection Officer through the following channels:

• Email: support@54jl.org (plain text — not a clickable link). Please include "Privacy Request" or "DPO" in your subject line.
• Live Chat: Available 24/7 on the 54jl platform. For privacy requests, ask to be connected to the Data Protection team.

54jl aims to respond to all privacy-related queries and data subject requests within 30 calendar days of receipt. Complex requests may require additional time, in which case you will be notified of the expected timeline.

If you are not satisfied with 54jl's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph). This right does not affect any other legal remedies available to you.